In Seabridge Gold Inc. v British Columbia, 2025 BCSC 558, a recent case argued by Thorsteinssons LLP, the British Columbia Supreme Court held that expenses incurred to assess the economic viability of a mineral resource are eligible for the…
Introduction
On March 26, 2025, the Tax Court of Canada (“TCC”) issued its decision in MEGlobal Canada ULC v. HMK. Following the recent decision of the Supreme Court of Canada (“SCC”) in Dow Chemical Canada ULC v. Canada.,…
The BC Court of Appeal and the BC Supreme Court have issued two recent judgments regarding the application of the additional property transfer tax (“ATT”), commonly called the BC foreign buyers tax, imposed under the Property Transfer Tax Act, RSBC…
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…