On November 5, 2026 (“Budget Day”), the federal government tabled its 2026 budget, Masters of our destiny (“Budget 2026”). The government presented the budget as advancing its plan to build a stronger, more competitive Canadian economy, with a stated…
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…
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…
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…
Yesterday (April 16, 2024), the Department of Finance Canada published its 2024 federal budget (“Budget 2024”). Several major tax proposals were announced. This blog post briefly outlines those relating to income tax.
1. Increased Capital Gains Inclusion Rate …
Filing a notice of objection is the first step a taxpayer must take to dispute an assessment or reassessment issued by the Minister of National Revenue (the “Minister”). Failure to follow the proper procedural rules for filing an objection can…