On June 29, 2021, Bill C-208 received Royal Assent. As previously discussed, that Bill amended the federal Income Tax Act (the “Act”) with the intention of facilitating intergenerational business transfers. The amendments sought to accomplish those means by, in…
Section 160 of the Income Tax Act (Canada) (the Act) is a collection tool that the Canada Revenue Agency (CRA) may use to collect unpaid tax debts of a taxpayer from third parties. This provision applies where a tax debtor…
In Zeifmans LLP v. MNR, 2021 FC 363, the Federal Court considered whether a requirement for information regarding unnamed persons issued to an accounting firm was properly made under section 231.2 of the Income Tax Act (Canada) (the “ITA”).…
The Tax Court’s decision in Leonard v. The Queen, 2021 TCC 33, analyzed the oft-discussed legal concept of “an adventure or concern in the nature of trade”, which the courts use to distinguish between transactions of a business nature…
On March 25, 2021, the Supreme Court of Canada (“SCC”) delivered its much-anticipated judgment on the constitutional validity of the Greenhouse Gas Pollution Pricing Act (“GGPPA”), the statute which enacts the federal government’s carbon pricing standard in relation to…
Authored by: Greg DelBigio, Q.C. and Morgan Watchorn
In Budget 2021, the federal government proposes to provide the Canada Revenue Agency (the “CRA”) with $230 million over five years as part of an ongoing focus on enforcing civil liabilities…
Authors: Alexander Demner, Tyler Berg, and Gloria Wang
The federal government released its 2021 budget on April 19, 2021. Coming in as the longest budget in Canadian history, Budget 2021 proposes a myriad of income tax…
In its 2020 Fall Economic Statement, the Canadian government announced that it would be moving forward with a unilateral approach to the taxation of digital services. This announcement came after years of discussions regarding a multilateral agreement on cross-border digital…
In February, the United States Department of Justice entered into a deferred prosecution agreement with Swiss bank, Rahn and Bodmer (R+B). The agreement refers to the criminal charge that R+B conspired with others to defraud the IRS, to file false…
On March 25, 2021, the Supreme Court of Canada (“SCC”) delivered its much-anticipated judgment on the constitutional validity of the Greenhouse Gas Pollution Pricing Act (“GGPPA”), the statute which enacts the federal government’s carbon pricing standard. In a 6-3…