On June 29, 2021, Bill C-208 received Royal Assent. As previously discussed, that Bill amended the federal Income Tax Act (the “Act”) with the intention of facilitating intergenerational business transfers. The amendments sought to accomplish those means by, in…
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…
On December 21, 2020, the Federal Court of Appeal (“FCA”) released its decision in Deyab v Canada, 2020 FCA 222 (“Deyab”), partly overturning the decision of the Tax Court of Canada (“TCC”). The FCA’s decision clarified that failing to…
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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…
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On July 27, 2020, Parliament enacted Bill C-20 which made sweeping amendments to the Canada Emergency Wage Subsidy (the “CEWS”). The…
Saskatchewan has introduced retroactive changes to their Provincial Sales Tax Act (“PSTA”) to require marketplace facilitators and operators of online accommodation platforms to register and collect Saskatchewan’s Provincial Sales Tax. The changes, which were announced on June 15th, are retroactive…
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I. OVERVIEW
On Saturday, April 11, 2020, Parliament – in a special sitting – enacted Bill C-14 to implement the Canada Emergency Wage Subsidy…
On March 25, 2020, the Ontario government released a one-year economic and fiscal update to respond to the COVID-19 public health crisis, in place of a full budget (see publication here). The update introduced the following tax measures designed…
The FAD Rules
Referred to as the foreign affiliate dumping (“FAD”) rules, section 212.3 was designed to restrict a non-resident corporation (a “parent”) from using a corporation resident in Canada (a “CRIC”) as an intermediary to invest in a…