Category: Withholding Tax

Finance Defers Implementation of Proposed Capital Gain Inclusion Rate Changes

Published by Thorsteinssons LLP

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…

Comprehensive Court Challenge to Proposed CRA Enforcement of Capital Gains Hike Launched

Published by David Davies & Alexander Demner & Florence Sauve & Morgan Watchorn

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…

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. …

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…

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…

Federal Court of Appeal Releases its decision in Univar Holdco Canada ULC. v. H.M.Q. 2017 FCA 207

Published by Leonard Gilbert

On October 13, 2017, the Federal Court of Appeal released its decision in Univar Holdco Canada ULC. v. H.M.Q. 2017 FCA 207 (“Univar”), overturning the trial decision at the Tax Court of Canada (2016 TCC 159). The judgment contained several…