I last wrote about the decision in BP Canada Energy Company v. Canada (National Revenue), 2017 FCA 61 on April 10, 2017. In that decision the Court imposed important restrictions upon the use of the s.231.1(1) audit powers by…
The Income Tax Act provides CRA with broad powers of administration and enforcement. In BP Energy Company v. Minister of National Revenue, 2017 FCA 61, the appeal court considered the authority to conduct the inspection of books and records given…
The BC government recently congratulated itself on the apparent effects of its controversial decision over the summer to impose an additional 15% property transfer tax on purchases of real estate in Metro Vancouver by foreign buyers. Since then, the…
If a year is to end with something that causes a bang, then the decision in Minister of National Revenue v. Iggillis Holdings Inc. and Ian Gillis Et Al., 2016 FC 1352 did just that. In reasons that are ambitious,…
In Alexander College Corp. v. Canada, 2016 FCA 269, the Federal Court of Appeal recently overturned the Tax Court of Canada on the issue of whether a private college offering an associate degree program must charge GST on its…
The so-called “anti-surplus stripping rule” in section 84.1 of the Income Tax Act (Canada) can apply where an individual taxpayer transfers shares of a corporation to another corporation with which the taxpayer does not deal at arm’s length. If the…
Almost since Tax-Free Savings Accounts (TFSAs) were first introduced in 2009, the Canada Revenue Agency (CRA) has been intent on clamping down on what it views as inappropriate activities undertaken within TFSAs. One area in particular has raised the ire…
Last week, the Canadian Department of Finance released proposed technical amendments to the Income Tax Act to deal with perceived deficiencies related to the housing market. Buried within those (very short, by technical amendment standards) changes is a suspension of…
It used to be that the favorite topic of conversation in Vancouver, and then more recently in Toronto was the cost of real estate. There was unending speculation on how high the prices might go and whether the party would…
The battle against perceived rampant real estate speculation continued when, on October 3, 2016, Canadian Finance Minister Bill Morneau released income tax amendments designed to “close loopholes” in the Income Tax Act related to the housing market. A relatively innocuous…