Budget 2024 proposed several amendments to the information gathering provisions in the Income Tax Act (the “Act”) intended to, as stated in the Supplementary Information regarding tax measures, “enhance the efficiency and effectiveness of tax audits and facilitate the…
Introduction
The Tax Court of Canada’s recent decision in Coopers Park Real Estate Development Corporation v His Majesty the King, 2024 TCC 122 (“Coopers Park”) serves as an important reminder of the unique and protected nature of privileged communications…
The British Columbia Supreme Court recently clarified the definition of “non-qualifying activity” under subsection 90(1) of the Provincial Sales Tax Exemption and Refund Regulation, BC Reg 97/2013 (the “PSTERR”) in Tolko Industries Ltd. v. British Columbia 2024 BCSC…
Yesterday (April 16, 2024), the Department of Finance Canada published its 2024 federal budget (“Budget 2024”). Several major tax proposals were announced. This blog post briefly outlines those relating to income tax.
1. Increased Capital Gains Inclusion Rate …
Filing a notice of objection is the first step a taxpayer must take to dispute an assessment or reassessment issued by the Minister of National Revenue (the “Minister”). Failure to follow the proper procedural rules for filing an objection can…
BC announced several proposed tax measures in its 2024 budget (released on February 22, 2024). Included in the long list of proposed changes – the more notable of which were summarized in our recent Tax Alert – are…
The Federal Court of Appeal (the “FCA”) recently released its decision in 3295940 Canada Inc v His Majesty The King, 2024 FCA 42. This decision is a welcome development in the jurisprudence regarding the application of the General Anti-Avoidance…
Tax and industry professionals have been waiting for the Federal Court of Appeal (the “FCA”) to issue its decision in Glencore Canada Corporation v R for several months. The decision under appeal (2021 TCC 63) sparked many discussions, and the…
I. INTRODUCTION
The Department of Finance first publicly announced an intention to modify the general anti-avoidance rule (the “GAAR”), found in section 245 of the Income Tax Act (Canada) (the “Act”), on November 30, 2020. This intention most recently came…
A recent decision from the British Columbia Supreme Court (“BCSC”), AF2G Investments Inc. v. Minister of Finance (BC), 2023 BCSC 2133, provided guidance on when a communication constitutes an objection under section 19 of the Property Transfer Tax Act,…