The Canada Revenue Agency (the “CRA”) is granted significant powers to gather information from persons under the Income Tax Act (Canada) (the “ITA”) and the Excise Tax Act (Canada) the (“ETA”), including the right to acquire and inspect documentation, enter…
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…
The BC Court of Appeal and the BC Supreme Court have issued two recent judgments regarding the application of the additional property transfer tax (“ATT”), commonly called the BC foreign buyers tax, imposed under the Property Transfer Tax Act, RSBC…
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…
Introduction
The Tax Court of Canada’s recent decision in Coopers Park Real Estate Development Corporation v His Majesty the King, 2024 TCC 122 (“Coopers Park”) serves as an important reminder of the unique and protected nature of privileged communications…
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…
Context: As part of the avalanche of new draft legislation, the Department of Finance has released revised excessive interest and financing expenses limitation (EIFEL) rules. The attached Excel is a high-level and technical summary of the new EIFEL regime. …
Budget 2023 – A Made-in-Canada Plan: Strong Middle Class, Affordable Economy, Healthy Future (“Budget 2023”) was tabled by the Department of Finance (“Finance”) on March 28, 2023 (“Budget Day”). The stated focus of Budget 2023 includes targeted inflation relief, stronger…