In the recent decision of Canada (National Revenue) v. Shopify Inc., 2025 FC 969 (“Shopify”), the Federal Court refused to authorize the Canada Revenue Agency (the “CRA”) to issue a so-called “unnamed person requirement” (“UPR”) to Shopify Inc. (the…
In Seabridge Gold Inc. v British Columbia, 2025 BCSC 558, a recent case argued by Thorsteinssons LLP, the British Columbia Supreme Court held that expenses incurred to assess the economic viability of a mineral resource are eligible for the…
Introduction
On March 26, 2025, the Tax Court of Canada (“TCC”) issued its decision in MEGlobal Canada ULC v. HMK. Following the recent decision of the Supreme Court of Canada (“SCC”) in Dow Chemical Canada ULC v. Canada.,…
The BC Court of Appeal and the BC Supreme Court have issued two recent judgments regarding the application of the additional property transfer tax (“ATT”), commonly called the BC foreign buyers tax, imposed under the Property Transfer Tax Act, RSBC…
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…
Yesterday, Thorsteinssons LLP (Canada’s largest tax law firm) launched a comprehensive challenge in Federal Court to the Canada Revenue Agency’s proposed enforcement of the capital gains tax hike. Led by David Davies, Alexander Demner, Florence Sauve, and…
Tax and industry professionals have been waiting for the Federal Court of Appeal (the “FCA”) to issue its decision in Glencore Canada Corporation v R for several months. The decision under appeal (2021 TCC 63) sparked many discussions, and the…
A recent decision from the British Columbia Supreme Court (“BCSC”), AF2G Investments Inc. v. Minister of Finance (BC), 2023 BCSC 2133, provided guidance on when a communication constitutes an objection under section 19 of the Property Transfer Tax Act,…
Earlier this week, the Supreme Court of Canada heard two tax appeals that may help clarify the jurisdictional boundaries between the Tax Court of Canada and Federal Court: Dow Chemical Canada ULC v His Majesty the King (SCC File No.…
When is an allocation of costs amongst supplies “fair and reasonable” for calculating input tax credits (“ITCs”)? In Marine Atlantic Inc. v The King (2023 TCC 95), the Tax Court confirmed that a “fair and reasonable” allocation:
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