On January 1, 2016, new rules relating to the taxation of trusts came into force in the form of subsections 104(13.3) and (13.4) of the Income Tax Act (Canada) (the “Act”). We have previously discussed the effect of…
I have had many hours of spirited conversation with my friend and colleague, Craig Sturrock Q.C., over the extent to which, or the way in which the Charter of Rights applies in tax law. In broad strokes, his position has…
By now you might have heard that Budget 2016 proposes to repeal the existing eligible capital property (“ECP”) regime in favour of a new class of depreciable capital property in respect of which capital cost allowance (“CCA”) may be claimed. …
The Honourable Marshall Rothstein, Q.C., who served on the Supreme Court of Canada from March 2006 to April 2015, spoke at a special meeting of the CBA Tax Section (BC Branch) on April 14, 2016. During his time on the…
As part of Budget 2016 the government announced that it is “committed to preventing underground economic activity, tax evasion and aggressive tax planning.” To achieve this, the budget proposes to allocate $444.4 million over five years to enable CRA to…
A spring break holiday provides one with a good opportunity to catch up on reading and to reflect upon basics. In this instance, the reading was the tax fraud prosecution of R. v. Khan and Muellenbach (2015 ONSC 7283) and…
The following blog was co-written by Brandon Wiener and Brent Pidborochynski.
On March 22, 2016, Prime Minister Justin Trudeau’s new federal government released its first budget (“Budget 2016”). Rumours of drastic changes to our tax system had been circulating in…
The fiscal plan upon which the Liberal Government was elected is set out in Growth for the Middle Class – The Liberal Fiscal Plan and Costing.[1]
Based on that document, and various speeches made during the election campaign, many small…
Last November, we blogged about the coming-into-force on January 1, 2016 of new subsection 104(13.4). We warned that the legislation, if not amended, would have a “catastrophic and devastating effect on many estate plans involving alter ego trusts, joint…
On February 4, 2016 the governments of Canada and Switzerland announced (http://www.fin.gc.ca/access/switzerland-declaration-suisse-eng.asp) that the two countries have signed a Joint Declaration expressing their intent to engage in the automatic exchange of financial information in accordance with the Common Reporting…