The Tax Court’s decision in Landbouwbedrijf Backx B.V. v. Canada, 2021 TCC 2 is a reminder to taxpayers that just because their filing position in a tax return is accepted by the Minister of National Revenue (the “Minister”), it…
In Paletta Estate v The Queen, 2021 TCC 11, the Tax Court of Canada allowed the taxpayer’s appeal in respect of “straddle” transactions undertaken in the early-2000s. In doing so, the Court expressly held that commercial activities undertaken solely…
On December 21, 2020, the Federal Court of Appeal (“FCA”) released its decision in Deyab v Canada, 2020 FCA 222 (“Deyab”), partly overturning the decision of the Tax Court of Canada (“TCC”). The FCA’s decision clarified that failing to…
Further to statements in the Fall Economic Statement, the Canada Revenue Agency has announced an administrative policy relating to the ability of employees to deduct home office expenses for the 2020 taxation year. The policy is temporary and made…
We last wrote about the Land Owner Transparency Act (“LOTA”) on May 23, 2019. On November 30, 2020, the BC Ministry of Finance announced that the LOTA registry has now launched.
In the announcement, the Ministry was unambiguous…
On November 30, 2020, the federal government presented its Fall Economic Statement (“FES”). The FES contains numerous noteworthy tax measures, including both pandemic-related financial support as well as longer-term tax changes.
The following summarizes the notable income tax measures…
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I. Overview
On November 19, 2020, Parliament enacted the Canada Emergency Rent Subsidy (“CERS”). Ostensibly designed to replace the underutilized Canada Emergency…
A recent American Bar Association Practice Point article posed the question: may tax evasion be charged as a money laundering offence? In Canada, the answer is unequivocally, yes – the acts that result in a charge of tax evasion…
Unlike most tax audits across the country, the pandemic has failed to disrupt audits under the City of Vancouver’s empty homes tax (“EHT”). Paradoxically, those audits appear to be increasing in recent months. More so than other audit types, EHT audits…
The Tax Court of Canada recently released its decision in Hansen v. The Queen, 2020 TCC 102, the latest in a quickly growing body of caselaw dealing with “house flips”. The case dealt with a taxpayer, Mr. Hansen, who…