On June 20, 2024, Bill C-69 received Royal Assent. As previously discussed, that Bill made several amendments to the federal Income Tax Act (the “Act”) including the introduction of section 67.7. In furtherance of the Bill’s stated intention…
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…
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 …
I. INTRODUCTION
The Department of Finance first publicly announced an intention to modify the general anti-avoidance rule (the “GAAR”), found in section 245 of the Income Tax Act (Canada) (the “Act”), on November 30, 2020. This intention most recently came…
Yesterday, the Department of Finance announced GST relief for new residential rental construction. In addition to signaling a reduction in the cost of supplying new rental homes, the measure potentially reduces or eliminates a major source of friction between…
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. …
The recently enacted “flipped property” rules in the Income Tax Act (Canada) (the “Act”) have wide ranging implications. Several tax practitioners have written about the problematic nature of the rules (see, for example: Evan Crocker and Kenneth Keung, “Related-Party Transfers…
The Canada Border Services Agency (“CBSA”) released a consultation paper and proposed regulations amending the Valuation for Duty Regulations on May 27, 2023, with a thirty-day consultation period that ends June 26, 2023. A copy of the proposed regulations…
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…