Last week, the Supreme Court of Canada (“SCC”) dismissed the Crown’s appeal in Canada v. Alta Energy Luxembourg S.A.R.L. (2021 SCC 49). In doing so, the SCC wrestled with important, timely, and politically contentious questions of domestic and international…
On June 29, 2021, Bill C-208 received Royal Assent. As previously discussed, that Bill amended the federal Income Tax Act (the “Act”) with the intention of facilitating intergenerational business transfers. The amendments sought to accomplish those means by, in…
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…
In its 2020 Fall Economic Statement, the Canadian government announced that it would be moving forward with a unilateral approach to the taxation of digital services. This announcement came after years of discussions regarding a multilateral agreement on cross-border digital…
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On July 27, 2020, Parliament enacted Bill C-20 which made sweeping amendments to the Canada Emergency Wage Subsidy (the “CEWS”). The…
On May 19, 2020 the CRA published administrative relief (found here) for taxpayers who might otherwise be facing Canadian tax residency or cross-border issues as a result of travel restrictions imposed in light of the COVID-19 crisis. Certain potential tax…
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I. OVERVIEW
On Saturday, April 11, 2020, Parliament – in a special sitting – enacted Bill C-14 to implement the Canada Emergency Wage Subsidy…
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…
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…