Section 231.2(1) of the ITA (and s.289(1) ETA) gives the Minister a broad power to compel the disclosure of information or documents. In language which imposes some but little restriction, the section provides that the Minister may “for any purpose…
The recent decision of the Tax Court of Canada (TCC) in Miedzi Cooper Corporation v. The Queen, 2015 TCC 26, should put to bed a needlessly ongoing debate with the Canada Revenue Agency (CRA) on the scope of input tax…
British Columbia is contemplating yet another change to its sales tax. The Province reverted from a federally collected Value Added Tax to a provincial sales tax (“PST”) on April 1, 2013. While the new PST is very similar to the…
On February 19, 2015, the federal government released proposed amendments to the Income Tax Regulations which would generally allow for accelerated capital cost allowance (“CCA”) treatment in respect of certain property used in connection with liquefying natural gas. The proposed…
It’s early 2015 and the CRA continues to aggressively audit Tax-Free Savings Accounts (TFSAs), going as far back as 2009 when TFSAs were first introduced. And why not? There is typically no time limit on issuing these types of assessments.…
Occasionally, the CRA agrees with a taxpayer, in advance, to assess tax in a particular way. Those agreements arise most frequently in the context of advance income tax rulings but, as in Szymczyk v. The Queen, 2014 TCC 380,…
On March 21, 2014, the Quebec Court of Appeal in the case of Canada (AG) and the Canada Revenue Agency v. Chambre des notaires du Quebec declared that subsection 231.2(1), section 231.7 and the definition of “solicitor-client privilege” in subsection…
In 2014-0534841C6, the CRA commented on the definition of majority-interest beneficiary in subsection 251.1(3) of the Income Tax Act. The CRA is of the view that a person does not have to be a beneficiary of a trust to…
The recent decision of Hauser v. R. 2014 TCC 328 is an illustration of the principles to be applied when determining whether moving expenses are deductible. The taxpayer moved in order to have a shorter commute to her new job. The…
On February 11, 2014, the federal government announced that it intended to repeal the so-called “immigrant trust” exception found in section 94 of the Income Tax Act (Canada) (the “ITA”). Due to the limited transitional rules provided (and no grandfathering),…