On December 3, 2021, a unanimous Supreme Court of Canada (“SCC”) dismissed the Crown’s appeal in Canada v. Loblaw Financial Holdings Inc. (2021 SCC 51). In doing so, the Court held that capital contributions and corporate oversight are not relevant…
In a unanimous decision, the Supreme Court of Canada has dismissed the Crown’s appeal in Canada v. Loblaw Financial Holdings Inc. (2021 SCC 51), holding that Loblaw Financial was entitled to rely on the financial institution exception set out in…
On November 25, 2021, the Honourable Eugene P. Rossiter provided an update on behalf of the Tax Court of Canada at the Canadian Tax Foundation’s 73rd Annual Tax Conference.
The Chief Justice commented on administrative matters at the Court and…
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…
On November 24, 2021, the Federal Government introduced Bill C-2 in Parliament to implement previously announced COVID-19 economic response measures aimed at industries and areas that may be particularly hard-hit by the pandemic’s lingering economic effects. This reflects a…
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…