The Province of Quebec announced today that it intends to expand its requirements for non-resident vendors to collect and remit Quebec Sales Tax (“QST”) on sales to Quebec consumers, effective as early as January 1, 2019. In this context “non-resident”…
In the 2018 Federal Budget, the Department of Finance released another chapter in its saga to overhaul how private corporations and their shareholders are taxed. Finance’s initial consultation paper of July 18, 2017 (see our summary here) was met…
BC’s Property Transfer Tax Act (“PTTA”) currently taxes only registered transfers of realty. In other words, it essentially taxes transfers of legal ownership, but not transfers of beneficial ownership. Numerous BC governments have for years considered expanding the scope of…
The meteoric rise, and subsequent tailspin, in the price of bitcoin has incited rampant investment in cryptocurrencies. Over 1,400 coins or tokens are now in “circulation”. Often lost in the resplendence and chicness of buying and selling cryptocurrencies are the…
The latest chapter in the story of the “half-loaf plan” has been penned by the Federal Court of Appeal in Gervais v. the Queen, 2018 FCA 3. The case dealt with a plan by which the taxpayer, Mr. Gervais,…
The Federal Court of Appeal recently released its decision in Canada (National Revenue) v. ConocoPhillips Canada Resources Corp., 2017 FCA 243. The background for the case is as follows: ConocoPhillips had been issued a reassessment of its 2000 taxation…
The Tax Court of Canada recently decided a new case under the general anti-avoidance rule (“GAAR”) in section 245 of the Income Tax Act. In Birchcliff Energy Ltd. v. The Queen, the Court held that the GAAR applied to restrict…
If you thought Vancouver’s vacancy tax (or “empty homes tax”) was a problem only for absentee condo owners, think again. A flaw in the scheme of the tax makes it a serious risk for virtually anyone who buys a home…
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…
Under the provisions of the Income Tax Act (the “ITA”), the CRA is authorized to inspect a taxpayer’s books and records and to require taxpayers to provide information and documents in the course of an income tax audit. However, the…