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,…
Earlier this week, the Supreme Court of Canada heard two tax appeals that may help clarify the jurisdictional boundaries between the Tax Court of Canada and Federal Court: Dow Chemical Canada ULC v His Majesty the King (SCC File No.…
Yesterday, the Department of Finance announced GST relief for new residential rental construction. In addition to signaling a reduction in the cost of supplying new rental homes, the measure potentially reduces or eliminates a major source of friction between…
Context: As part of the avalanche of new draft legislation, the Department of Finance has released revised excessive interest and financing expenses limitation (EIFEL) rules. The attached Excel is a high-level and technical summary of the new EIFEL regime. …