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…
According to data available on its website, the Canada Revenue Agency (the “CRA”) completed approximately 12,000 “real estate” audits in British Columbia for both income tax and goods and services tax/harmonized sales tax (“GST/HST”) between April 2015 and March…
In Ahamed v. The King (“Ahamed”), the Tax Court of Canada held that a tax-free savings account (“TFSA”), despite its moniker, is capable of carrying on a business of trading securities and any income earned from that business is fully…
The Court of Justice for the European Union (CJEU) recently invalidated a provision derived from the EU Directive informally known as DAC6 which requires lawyers to report their involvement in certain cross-border tax-planning arrangements to third parties. The provisions analyzed…
Khanna v. The Queen, 2022 FCA 84 is an important decision of the Federal Court of Appeal (the “FCA”) on the topic of gross-negligence penalties imposed under subsection 163(2) of the Income Tax Act (Canada) (the “Act”). The decision…
When a real property held by a taxpayer as a rental property becomes the taxpayer’s residence (or vice versa), the “change-in-use” rules in section 45 and subsection 13(7) of the Income Tax Act (the “ITA”) are triggered. Subsection 45(1) provides…
In Canada v Paletta Estate (“Paletta FCA”), a unanimous panel of the Federal Court of Appeal (the “FCA”) overturned the decision of the Tax Court of Canada (“Paletta TCC”). Our blog post analyzing Paletta TCC is found