On June 4, 2026, the Supreme Court of Canada (“SCC”) dismissed the application for leave to appeal of three poker players in Philippe D’Auteuil, et al. v. His Majesty the King (case number 41975). The application for leave followed…
On September 15, 2026, the federal government announced the Productivity Mega Deduction (the “Mega Deduction”) at the first Canada Investment Summit (see the Prime Minister’s release). The Department of Finance (“Finance”) issued a news release describing the measure…
The federal government initially proposed significant changes to the Canada Revenue Agency’s (the “CRA”) audit powers under the Income Tax Act (the “Act”) in Budget 2024 (see Proposed legislation expanding the CRA’s audit powers: pitfalls and takeaways and…
The Income Tax Act (Canada) (the “ITA”)) contains strict requirements for notices of objection filed by a “large corporation”. A recent Tax Court of Canada (“TCC”) decision – 941624 Alberta Ltd v R, 2026 TCC 67 – illustrates that…
Following our previous discussion of Canadian tax residency, this post explores the next question: what happens when a taxpayer becomes a non-resident of Canada under the Income Tax Act (Canada) (the “ITA”)?
Whether a taxpayer’s “exit” is tax motivated or…
Under the Income Tax Act (Canada) (the “ITA”), a resident of Canada is taxable on worldwide income, whereas a non-resident is taxable only on certain income that is connected to Canada. Non-residents are also subject to withholding tax on certain…
At the 2025 CTF Annual Tax Conference, during their annual 2025 roundtable (the “2025 Roundtable”) the Canada Revenue Agency (the “CRA”) answered questions regarding its current administrative views and practices. This blog provides an overview of certain key takeaways from…
Overview
Tax disputes generally hinge on whether the imposition of taxes and penalties is correct. However, there are situations where a taxpayer can be granted relief from the imposition of penalties and/or interest even if they were correctly levied. Subsection…
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…
On June 20, 2024, Bill C-69 received Royal Assent. As previously discussed, that Bill made several amendments to the federal Income Tax Act (the “Act”) including the introduction of section 67.7. In furtherance of the Bill’s stated intention…