On June 20, 2024, Bill C-69 received Royal Assent. As previously discussed, that Bill made several amendments to the federal Income Tax Act (the “Act”) including the introduction of section 67.7. In furtherance of the Bill’s stated intention…
On Friday, in the face of mounting pressure – including a court application launched by Thorsteinssons LLP – the Department of Finance (Finance) announced that the implementation date for the proposed capital gains inclusion rate changes would be…
Yesterday, Thorsteinssons LLP (Canada’s largest tax law firm) launched a comprehensive challenge in Federal Court to the Canada Revenue Agency’s proposed enforcement of the capital gains tax hike. Led by David Davies, Alexander Demner, Florence Sauve, and…
The Canada Revenue Agency (CRA) recently announced that, starting in the spring of 2025, it will transition to using the CRA’s online portal for businesses (My Business Account) as the default method of sending correspondence to businesses, instead of…
On December 20, 2024, the CRA published its views on the general anti-avoidance rule (GAAR) in a new webpage. The webpage contains some general comments by the CRA regarding the GAAR, examples of when the CRA would apply the…
Yesterday, the CRA announced it will not require bare trusts to file a T3 Income Tax and Information Return (including Schedule 15 Beneficial Ownership Information of a Trust) for their 2024 taxation year, unless the CRA directly requests such…
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…
Subsection 215(1) of the Income Tax Act (the “Act”) imposes on Canadian tenants the obligation to withhold and remit Part XIII tax on residential rent paid to non-resident landlords. The applicable tax rate is 25% of the gross rent paid,…
On June 20, 2024, Bill C-59 and Bill C-69 each received Royal Assent. Together, they make sweeping changes to the federal Income Tax Act (the “Act”) that taxpayers and their advisors simply must know. The below chart notes…