Finance Minister Chrystia Freeland announced today that the 2023 Federal Budget will be presented on March 28, 2023. Although the federal government’s 2022 Fall Economic Statement signalled its intention to proceed with a number of previously announced tax measures, it…
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…
The FAD Rules
Referred to as the foreign affiliate dumping (“FAD”) rules, section 212.3 was designed to restrict a non-resident corporation (a “parent”) from using a corporation resident in Canada (a “CRIC”) as an intermediary to invest in a…