British Columbia is the last province in Canada to introduce marketplace facilitator rules that will require online marketplace facilitators rather than sellers to collect BC PST on sales made through the marketplace. The proposed legislation is to come into force…
Authors: Gloria Wang, Sarah Faber, and Alexander Demner
Budget 2022: A Plan to Grow Our Economy and Make Life More Affordable (“Budget 2022”) was tabled by the Federal Government on April 7, 2022 (“Budget Day”). The government…
Authors: Jennifer Flood and Greg DelBigio, Q.C.
The 2022 Budget shows once again Canada’s ongoing commitment to the investigation and prosecution of financial crime including money laundering and tax evasion, including by injecting substantial funds into expanding the…
Under the Excise Tax Act (the “Act”), the Minister of National Revenue (“Minister”) and her delegates are granted discretion to make administrative decisions affecting taxpayers on a case-by-case basis, including powers to extend deadlines or waive compliance with certain requirements…
In a prior blog post, we discussed the decision of the BC Supreme Court (“BCSC”) in Chemainus Gardens RV Resort Ltd. v. British Columbia (Attorney General), 2020 BCSC 478. The case is of particular interest because it rejected the…
The federal government provided its 2021 Economic and Fiscal Update on December 14, 2021. Amidst numerous new legislative measures introduced was the newly-proposed underused housing tax (the “UHT”). Draft legislation, in the form of a new Underused Housing Tax Act…
On December 3, 2021, a unanimous Supreme Court of Canada (“SCC”) dismissed the Crown’s appeal in Canada v. Loblaw Financial Holdings Inc. (2021 SCC 51). In doing so, the Court held that capital contributions and corporate oversight are not relevant…
Last week, the Supreme Court of Canada (“SCC”) dismissed the Crown’s appeal in Canada v. Alta Energy Luxembourg S.A.R.L. (2021 SCC 49). In doing so, the SCC wrestled with important, timely, and politically contentious questions of domestic and international…
Canada taxes its residents on their worldwide income, including income earned and gains realized outside Canada (subject to the potential application of specific rules in tax treaties). The federal Income Tax Act (the “ITA”) also requires that residents disclose specific…
In Canada (National Revenue) v. Boguski, 2021 FCA 118 affirming 2018 TCC 236, the Federal Court of Appeal (the “FCA”) affirmed the decision of the Tax Court of Canada (the “Tax Court”) to dismiss the Minister’s application for an…