In Ahamed v. The King (“Ahamed”), the Tax Court of Canada held that a tax-free savings account (“TFSA”), despite its moniker, is capable of carrying on a business of trading securities and any income earned from that business is fully…
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…
The Canada Revenue Agency (“CRA”) has announced additional tax relief measures as part of its response to the ongoing COVID-19 crisis. These measures are summarized below.
Administrative Tax Measures
The new measures extend various filing deadlines under the Income Tax…
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…
The Tax Court of Canada decision in Lee v The Queen, 2018 TCC 230 clarified the concept of sham in the context of transactions undertaken to give effect to a tax plan. The decision draws a line between tax avoidance…