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…
Authored by: Greg DelBigio, Q.C. and Morgan Watchorn
In Budget 2021, the federal government proposes to provide the Canada Revenue Agency (the “CRA”) with $230 million over five years as part of an ongoing focus on enforcing civil liabilities…
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…
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…
Further to statements in the Fall Economic Statement, the Canada Revenue Agency has announced an administrative policy relating to the ability of employees to deduct home office expenses for the 2020 taxation year. The policy is temporary and made…
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…
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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…
On June 23, 2020, the CRA released its National Business Resumption Plan (the “NBRP”) for CRA employees. This follows the CRA’s previous announcement that it would be transitioning from a critical services mode to a business resumption mode on June…
On May 19, 2020 the CRA published administrative relief (found here) for taxpayers who might otherwise be facing Canadian tax residency or cross-border issues as a result of travel restrictions imposed in light of the COVID-19 crisis. Certain potential tax…