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…
In response to the ongoing COVID-19 pandemic, the BC government has declared a state of emergency. The Province has taken several steps to address the challenges that the pandemic presents.[1]
Both filing deadlines and payment deadlines for:
…
On March 18, 2020, the Department of Finance announced the COVID-19 Economic Response Plan (“the COVID-19 ERP”) designed to help Canadians facing hardship as a result of the COVID-19 outbreak.
This post focuses on the tax-related measures contained in the…
The SCC decision in Canada (Minister of Citizenship and Immigration) v Vavilov (2019 SCC 65) (“Vavilov”) and its companion case Bell Canada v. Canada (Attorney General) (2019 SCC 66) established a new framework that Courts must follow when reviewing decisions…
In Gidda (Re), 2020 BCSC 121, the Supreme Court of British Columbia affirmed the Crown’s priority as a secured creditor in bankruptcy proceedings, insofar as the registration of a tax debt judgment against the bankrupt’s interests in property is made…
On February 24, 2020, the Alberta Court of Appeal became the third court in Canada to rule on the federal government’s carbon pricing regime. Unlike previous cases in Saskatchewan and Ontario, the Alberta Court held that the…
In White v The Queen[1], the Tax Court allowed Mrs. White’s appeal, holding that the deposits of funds by Mr. White, a “tax debtor”, into a joint bank account held by him and Mrs. White (the “Joint Bank…
In Scott v The Queen, 2020 TCC 4, the Tax Court of Canada held that a transferee’s liability in a section 160 assessment was reduced where, after the assessment, the Minister of National Revenue (the “Minister”) cancelled a portion…
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…
In Canada v Rio Tinto Alcan[1], the Federal Court of Appeal (“FCA”) upheld the Tax Court of Canada (“TCC”) decision[2] confirming, inter alia, the deductibility of certain takeover expenses incurred by Rio Tinto Alcan Inc. (“Alcan”)…