Category: Tax Residency

SCC Dismisses Crown Appeal in Alta Energy Case

Published by Chris Marta & Alexei Paish & Sarah Faber

Last week, the Supreme Court of Canada (“SCC”) dismissed the Crown’s appeal in Canada v. Alta Energy Luxembourg S.A.R.L. (2021 SCC 49). In doing so, the SCC wrestled with important, timely, and politically contentious questions of domestic and international…

2021 Federal Budget – A Critical Analysis and Overview of the Principal Proposed Income Tax Measures

Published by Thorsteinssons LLP

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…

Landbouwbedrijf – Tax Court reiterates that the Minister of National Revenue is not precluded from challenging a taxpayer’s previously-accepted filing position

Published by Milan Vukovic

The Tax Court’s decision in Landbouwbedrijf Backx B.V. v. Canada, 2021 TCC 2 is a reminder to taxpayers that just because their filing position in a tax return is accepted by the Minister of National Revenue (the “Minister”), it…

COVID-19 Tax Update: CRA administrative relief regarding residency and cross-border issues

Published by Jenna Himelfarb

On May 19, 2020 the CRA published administrative relief (found here) for taxpayers who might otherwise be facing Canadian tax residency or cross-border issues as a result of travel restrictions imposed in light of the COVID-19 crisis. Certain potential tax…