The Tax Court’s decision in Leonard v. The Queen, 2021 TCC 33, analyzed the oft-discussed legal concept of “an adventure or concern in the nature of trade”, which the courts use to distinguish between transactions of a business nature…
On March 25, 2021, the Supreme Court of Canada (“SCC”) delivered its much-anticipated judgment on the constitutional validity of the Greenhouse Gas Pollution Pricing Act (“GGPPA”), the statute which enacts the federal government’s carbon pricing standard in relation to…
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…
On March 25, 2021, the Supreme Court of Canada (“SCC”) delivered its much-anticipated judgment on the constitutional validity of the Greenhouse Gas Pollution Pricing Act (“GGPPA”), the statute which enacts the federal government’s carbon pricing standard. In a 6-3…
In Paletta Estate v The Queen, 2021 TCC 11, the Tax Court of Canada allowed the taxpayer’s appeal in respect of “straddle” transactions undertaken in the early-2000s. In doing so, the Court expressly held that commercial activities undertaken solely…
On November 30, 2020, the federal government presented its Fall Economic Statement (“FES”). The FES contains numerous noteworthy tax measures, including both pandemic-related financial support as well as longer-term tax changes.
The following summarizes the notable income tax measures…
The recent decision of Bishara c. Agence du revenu du Québec[1] is a win for a taxpayer on the sale of three condominiums in quick succession. This decision is unusual because the Quebec Court of Appeal (“QCA”) reversed the decision…
At the end of March, the BC Supreme Court released its decision in Chemainus Gardens RV Resort Ltd. v The Queen, 2020 BCSC 478. The decision is potentially of great assistance to contractors in BC who install goods that become…
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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…
The decision in Grewal v Canada (National Revenue) involved a taxpayer being penalized in respect of amounts disclosed in a voluntary disclosure, despite the fact that the disclosure was accepted by the Canada Revenue Agency (“CRA”).
This case addressed…