On Friday, in the face of mounting pressure – including a court application launched by Thorsteinssons LLP – the Department of Finance (Finance) announced that the implementation date for the proposed capital gains inclusion rate changes would be…
On June 20, 2024, Bill C-59 and Bill C-69 each received Royal Assent. Together, they make sweeping changes to the federal Income Tax Act (the “Act”) that taxpayers and their advisors simply must know. The below chart notes…
The Canada Revenue Agency (“CRA”) announced today that – “in recognition that the new reporting requirements for bare trusts have had an unintended impact on Canadians” – it will not require bare trusts to file a T3 income tax…
In Gestion M.-A. Roy Inc. c Canada (2024 FCA 16), the Federal Court of Appeal agreed with the Tax Court that the corporate holders of two life insurance policies received taxable benefits where the premiums of both policies were paid…
On June 22, 2023, Bill C-47 received Royal Assent, bringing into force new or expanded mandatory reporting rules for certain “reportable” or “notifiable” transactions (the “Mandatory Disclosure Rules”). The Mandatory Disclosure Rules require taxpayers, promoters and certain advisors (including legal…
On July 24, 2023, the Canada Revenue Agency (CRA) released the new and revised forms applicable to the enhanced mandatory disclosure rules under the Income Tax Act (Canada) (the “Act”).
The CRA has published two separate documents relating to the new and expanded mandatory disclosure rules, which became law on June 22, 2023. For discussion of those rules, see our previous tax alert and blog post.
The first…
On June 22, 2023, Bill C-47 – An Act to implement certain provisions of the budgets tabled in Parliament on March 28, 2023 received Royal Assent. As a consequence, new or expanded mandatory reporting rules for certain “reportable” or “notifiable”…
The amendments to section 84.1 implemented by Bill C-208 (43rd Parliament, 2nd session) permit intergenerational share transfers to corporations controlled by a child or grandchild to be executed on a tax-efficient basis. If certain conditions are met, parents and grandparents…
Authors: Gloria Wang, Sarah Faber, and Alexander Demner
Budget 2022: A Plan to Grow Our Economy and Make Life More Affordable (“Budget 2022”) was tabled by the Federal Government on April 7, 2022 (“Budget Day”). The government…