Authors: Jennifer Flood and Greg DelBigio, Q.C.
The 2022 Budget shows once again Canada’s ongoing commitment to the investigation and prosecution of financial crime including money laundering and tax evasion, including by injecting substantial funds into expanding the…
In Nicole L. Tiessen Interior Design LTD. v Canada (2021 TCC 29), the Tax Court of Canada (“TCC”) found that 30 corporations were deemed to be associated with each other under the anti-avoidance rule in s. 256(2.1) of the federal…
The Supreme Court of Canada (the “SCC”) has granted the application for leave to appeal in Canada v. Deans Knight Income Corporation, 2021 FCA 160 (“Deans Knight”).
Deans Knight deals with the application of the general anti-avoidance rule (“GAAR”)…
In a unanimous decision, the Supreme Court of Canada has dismissed the Crown’s appeal in Canada v. Loblaw Financial Holdings Inc. (2021 SCC 51), holding that Loblaw Financial was entitled to rely on the financial institution exception set out in…
On November 25, 2021, the Honourable Eugene P. Rossiter provided an update on behalf of the Tax Court of Canada at the Canadian Tax Foundation’s 73rd Annual Tax Conference.
The Chief Justice commented on administrative matters at the Court and…
On November 24, 2021, the Federal Government introduced Bill C-2 in Parliament to implement previously announced COVID-19 economic response measures aimed at industries and areas that may be particularly hard-hit by the pandemic’s lingering economic effects. This reflects a…
The Supreme Court of Canada has dismissed the Crown’s appeal in Canada v. Alta Energy Luxembourg S.A.R.L.(2021 SCC 49). The Court concluded that the Minister of National Revenue did not discharge her burden of proving abusive tax avoidance in…
On November 4, 2021, the Province of Ontario released its 2021 Fall Economic Update. Under the heading “Fighting Financial Crimes and Tax Evasion”, the government proposed new beneficial ownership information requirements for privately held corporations under the Ontario Business Corporations…
Authored by: Greg DelBigio, Q.C. and Morgan Watchorn
In Budget 2021, the federal government proposes to provide the Canada Revenue Agency (the “CRA”) with $230 million over five years as part of an ongoing focus on enforcing civil liabilities…
Authors: Alexander Demner, Tyler Berg, and Gloria Wang
The federal government released its 2021 budget on April 19, 2021. Coming in as the longest budget in Canadian history, Budget 2021 proposes a myriad of income tax…