Category: Tax Legislation Updates

What’s new? The latest evolution in the GAAR “modernization” proposals

Published by Molly Martin

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…

Quick Update – New EIFEL Regime

Published by Ian Gamble

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. …

Inadvertently caught in the net – deemed dispositions and the “flipped property” rules

Published by Ken Jiang & Justin Shoemaker

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…

Principal tax measures from Federal Budget 2023 – Part 3: Clean energy initiatives

Published by Alexei Paish & Asif Abdulla & Gloria Wang

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…

Principal tax measures from Federal Budget 2023 – Part 2: Public company and financial institution measures

Published by Alexei Paish & Gloria Wang & Asif Abdulla

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…

Principal tax measures from Federal Budget 2023 – Part 1: Personal and private company measures

Published by Alexei Paish & Asif Abdulla & Gloria Wang

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…

House flipping: refresher and practical advice – Part 1: income tax

Published by Tyler Berg

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…