The Supreme Court of Canada has dismissed the Crown’s appeal in Canada v. Alta Energy Luxembourg S.A.R.L.(2021 SCC 49). The Court concluded that the Minister of National Revenue did not discharge her burden of proving abusive tax avoidance in…
The Federal Court of Appeal recently outlined the correct appeal routes for employers who are denied a Canada Emergency Wage Subsidy (the “CEWS”) claim by the Canada Revenue Agency.
In general terms, the CEWS functions by deeming a qualifying employer…
On November 4, 2021, the Province of Ontario released its 2021 Fall Economic Update. Under the heading “Fighting Financial Crimes and Tax Evasion”, the government proposed new beneficial ownership information requirements for privately held corporations under the Ontario Business Corporations…
The B.C. Government has extended by one year the deadline for pre-existing owners of a registered interest in land that are reporting bodies to file a transparency report with the Land Owner Transparency Registry (the “Registry”). Prior to the extension,…
Canada taxes its residents on their worldwide income, including income earned and gains realized outside Canada (subject to the potential application of specific rules in tax treaties). The federal Income Tax Act (the “ITA”) also requires that residents disclose specific…
In Canada (National Revenue) v. Boguski, 2021 FCA 118 affirming 2018 TCC 236, the Federal Court of Appeal (the “FCA”) affirmed the decision of the Tax Court of Canada (the “Tax Court”) to dismiss the Minister’s application for an…
The Federal Court of Appeal (the “FCA”) recently released its highly anticipated decision in Canada v. Deans Knight Income Corporation, 2021 FCA 160. The case represents the FCA’s first consideration of an alleged abuse of the “control” threshold for…
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…
Section 160 of the Income Tax Act (Canada) (the Act) is a collection tool that the Canada Revenue Agency (CRA) may use to collect unpaid tax debts of a taxpayer from third parties. This provision applies where a tax debtor…
In Zeifmans LLP v. MNR, 2021 FC 363, the Federal Court considered whether a requirement for information regarding unnamed persons issued to an accounting firm was properly made under section 231.2 of the Income Tax Act (Canada) (the “ITA”).…