The Income Tax Act (Canada) (the “ITA”)) contains strict requirements for notices of objection filed by a “large corporation”. A recent Tax Court of Canada (“TCC”) decision – 641624 Alberta Ltd v R, 2026 TCC 67 – illustrates that…
The City of Toronto appears to be ramping up its Vacant Home Tax (VHT) audit program. While historically there has been minimal compliance or enforcement activity undertaken, as of March 4, 2024 a total of 466 properties were under audit…
The Federal Court of Appeal (the “FCA”) recently released its decision in 3295940 Canada Inc v His Majesty The King, 2024 FCA 42. This decision is a welcome development in the jurisprudence regarding the application of the General Anti-Avoidance…
On March 27, 2023, the Federal government announced important changes to the Foreign Home Buyers Ban, which came into effect on January 1, 2023. We previously published a detailed tax alert explaining the Foreign Home Buyers Ban. The new…
On November 3, 2022, the Federal Government released its Fall Economic Statement 2022 (the “Statement”). In the Statement, the government reaffirmed its commitment to various tax measures it previously announced, including rules relating to substantive Canadian-controlled private corporations and…
On November 3, 2022, the Department of Finance released revised draft legislation proposing to implement the “excessive interest and financing expenses limitation” (EIFEL) rules first announced in Budget 2021. Initial draft legislation was released on February 4, 2022 and…
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…