Canada taxes its residents on their worldwide income, including income earned and gains realized outside Canada (subject to the potential application of specific rules in tax treaties). The federal Income Tax Act (the “ITA”) also requires that residents disclose specific…
The Tax Court recently released an important decision regarding the relevance test for production of documents and information during discoveries. In Thompson Bros. (Constr.) Ltd. v. The Queen, 2021 TCC 15 (“Thompson Bros.”), the Tax Court was asked to…
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On July 27, 2020, Bill c-20 An Act respecting further COVID-19 measures was enacted. This legislation includes the Time Limits and Other Periods Act…
As part of its COVID-19 Economic Response Plan, the Government has taken a number of steps to alleviate hardships faced by taxpayers. As discussed in our previous blog post, these measures include filing deadline extensions and payment deferrals to…
On March 18, 2020, the Department of Finance announced the COVID-19 Economic Response Plan (“the COVID-19 ERP”) designed to help Canadians facing hardship as a result of the COVID-19 outbreak.
This post focuses on the tax-related measures contained in the…
The SCC decision in Canada (Minister of Citizenship and Immigration) v Vavilov (2019 SCC 65) (“Vavilov”) and its companion case Bell Canada v. Canada (Attorney General) (2019 SCC 66) established a new framework that Courts must follow when reviewing decisions…
In Gidda (Re), 2020 BCSC 121, the Supreme Court of British Columbia affirmed the Crown’s priority as a secured creditor in bankruptcy proceedings, insofar as the registration of a tax debt judgment against the bankrupt’s interests in property is made…
In White v The Queen[1], the Tax Court allowed Mrs. White’s appeal, holding that the deposits of funds by Mr. White, a “tax debtor”, into a joint bank account held by him and Mrs. White (the “Joint Bank Account”) did…
In Canada v Rio Tinto Alcan[1], the Federal Court of Appeal (“FCA”) upheld the Tax Court of Canada (“TCC”) decision[2] confirming, inter alia, the deductibility of certain takeover expenses incurred by Rio Tinto Alcan Inc. (“Alcan”) in its takeover of…
The Tax Court of Canada decision in Lee v The Queen, 2018 TCC 230 clarified the concept of sham in the context of transactions undertaken to give effect to a tax plan. The decision draws a line between tax avoidance…