On August 4, 2023, the Department of Finance released draft legislative proposals relating to certain measures that were announced as part of the 2023 federal budget (“Budget 2023”) as well as other previously-announced measures. Included is draft legislation on…
The CRA has published two separate documents relating to the new and expanded mandatory disclosure rules, which became law on June 22, 2023. For discussion of those rules, see our previous tax alert and blog post.
The first…
On June 22, 2023, Bill C-47 – An Act to implement certain provisions of the budgets tabled in Parliament on March 28, 2023 received Royal Assent. As a consequence, new or expanded mandatory reporting rules for certain “reportable” or “notifiable”…
On June 20, 2023, the Province of British Columbia (the “Province”) released a Provincial Sales Tax (PST) Notice to providers and purchasers of cloud software and services (the “Notice”). The Notice came in response to the B.C. Supreme Court…
The amendments to section 84.1 implemented by Bill C-208 (43rd Parliament, 2nd session) permit intergenerational share transfers to corporations controlled by a child or grandchild to be executed on a tax-efficient basis. If certain conditions are met, parents and grandparents…
Today, by a 7:1 majority, the Supreme Court of Canada dismissed the appeal of Deans Knight Income Corporation (“Deans Knight”) from a 2021 decision of the Federal Court of Appeal that upheld the application of the general anti-avoidance…
On March 27, 2023, the Federal government announced important changes to the Foreign Home Buyers Ban, which came into effect on January 1, 2023. We previously published a detailed tax alert explaining the Foreign Home Buyers Ban. The new…
Finance Minister Chrystia Freeland announced today that the 2023 Federal Budget will be presented on March 28, 2023. Although the federal government’s 2022 Fall Economic Statement signalled its intention to proceed with a number of previously announced tax measures, it…
A loan or indebtedness which meets the following statutory requirements is generally referred to as a “prescribed rate loan”:
(a) interest is charged on the loan or indebtedness at a rate equal to or greater than the lesser…
The Prohibition on the Purchase of Residential Property by Non-Canadians Act (the “Act”) enters into force this Sunday (January 1, 2023). As supplemented by detailed regulations (the “Regulations”), the Act prohibits any “non-Canadian” from purchasing, directly or indirectly,…