Authors: Gloria Wang, Sarah Faber, and Alexander Demner
Budget 2022: A Plan to Grow Our Economy and Make Life More Affordable (“Budget 2022”) was tabled by the Federal Government on April 7, 2022 (“Budget Day”). The government…
Authors: Jennifer Flood and Greg DelBigio, Q.C.
The 2022 Budget shows once again Canada’s ongoing commitment to the investigation and prosecution of financial crime including money laundering and tax evasion, including by injecting substantial funds into expanding the…
Canada taxes its residents on their worldwide income, including income earned and gains realized outside Canada (subject to the potential application of specific rules in tax treaties). The federal Income Tax Act (the “ITA”) also requires that residents disclose specific…
In Canada (National Revenue) v. Boguski, 2021 FCA 118 affirming 2018 TCC 236, the Federal Court of Appeal (the “FCA”) affirmed the decision of the Tax Court of Canada (the “Tax Court”) to dismiss the Minister’s application for an…
In Zeifmans LLP v. MNR, 2021 FC 363, the Federal Court considered whether a requirement for information regarding unnamed persons issued to an accounting firm was properly made under section 231.2 of the Income Tax Act (Canada) (the “ITA”).…
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…
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…
The CRA is expected to soon commence audit activities to review payments made pursuant to three of Canada’s COVID-19 relief programs: the Canada Emergency Wage Subsidy (“CEWS”), the Canada Emergency Response Benefit (“CERB”), and the Canada Emergency Student Benefit (“CESB”).…
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On July 27, 2020, Bill c-20 An Act respecting further COVID-19 measures was enacted. This legislation includes the Time Limits and Other Periods Act…