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…
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…
On February 24, 2020, the Alberta Court of Appeal became the third court in Canada to rule on the federal government’s carbon pricing regime. Unlike previous cases in Saskatchewan and Ontario, the Alberta Court held that the…