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On November 19, 2020, Parliament enacted the Canada Emergency Rent Subsidy (“CERS”). Ostensibly designed to replace the underutilized Canada Emergency…
Context: In 1982 the CRA published its position on barter transactions, describing them as transactions “effected when any two persons agree to a reciprocal exchange of goods or services and carry out that exchange usually without using money”: IT-490. This…
Yesterday, the CBC reported that the CRA has transferred more than 1.6 million Canadian banking records to the United States Internal Revenue Service (“IRS”) since an information sharing agreement was entered into between the two countries in 2014. The…
On July 18, 2017, the Department of Finance released its consultation policy paper on the taxation of private corporations first announced in Budget 2017, along with proposed legislation on some of the topics addressed.
The Minister’s introductory letter acknowledges the…
On January 1, 2016, new rules relating to the taxation of trusts came into force in the form of subsections 104(13.3) and (13.4) of the Income Tax Act (Canada) (the “Act”). We have previously discussed the effect of…
This blog was co-authored by Simon Thang and Rosemary Anderson.
Time is running out to file an important Goods and Services Tax (GST/HST) election form that, until recently, was not required to be filed.
Specifically, Canadian corporations and partnerships that…
In a case of what could be considered “good news/bad news,” certain naturopathic and acupuncturist services became GST/HST-exempt effective February 12, 2014. The Canada Revenue Agency (“CRA”) recently released its administrative interpretation of these new exemptions (see Technical Information Bulletin…
In Discovery Trust v. Minister of National Revenue, 2015 NLTD(G)86, the Newfoundland Supreme Court issued Canada’s first decision involving the provincial residency of a trust. This is also the first decision to apply the test for trust residency articulated…
Suppose you disagree with a CRA assessment and appeal the issue to the Tax Court. Suppose you lose the case. And suppose you decide the court is wrong in its reasoning and file your next tax return on the basis…
Murphy’s Law is, as everyone knows, the proposition that “Anything that can possibly go wrong, does.” There are many variants of this. Among tax practitioners, a well known one is the proposition “There is no equity in a tax statute.”…