The Australian Taxation Office (ATO) recently announced that, through a consultation process, it is examining the use and, more particularly, what it says are occasions of misuse of claims of solicitor-client privilege. The Consultation is interesting but, it also provides…
Several weeks ago the Vancouver city council passed a motion instructing its staff to develop a plan that would “improve the fairness and effectiveness of the Empty Homes Tax [or EHT]…”. This would require a review of “the fairness and…
Yesterday, the CBC reported that the CRA has transferred more than 1.6 million Canadian banking records to the United States Internal Revenue Service (“IRS”) since an information sharing agreement was entered into between the two countries in 2014. The…
The Tax Court of Canada decision in Lee v The Queen, 2018 TCC 230 clarified the concept of sham in the context of transactions undertaken to give effect to a tax plan. The decision draws a line between tax avoidance…
Earnings within Tax-Free Savings Accounts (TFSAs) and other tax-deferred plans are, in principle, supposed to grow “tax-free”. However, some taxes can still apply. One such tax is the advantage tax which applies at the rate of 100% of any advantage…
Taxes on residential realty in and around Greater Vancouver have been steadily proliferating over the past few years: first the provincial Foreign Buyer Tax (2016), then the municipal Vacancy Tax (2017) and, most recently, the provincial Speculation Tax (2018). All…
Last week the BC government tabled Bill 45, which seeks to implement the province’s new Speculation and Vacancy Tax. A careful review of the Bill suggests that it is overreaching and lacking in taxpayer fairness. Critical aspects of the…
The recent Federal Court decision in Canada (National Revenue) v. Hydro-Québec, 2018 FC 622 made a strong statement against an interpretation of the CRA’s powers that would allow virtually unlimited invasions of taxpayer privacy. The decision considered the scope of…
In these heady days of cryptocurrency investment, the market can seem like a gold rush: offering promise, but at the expense of predictability. The taxation of cryptocurrencies is no different. In this article, a collaboration between the Fintech Team…
For the past few months, the City of Vancouver has been conducting audits to verify the 2017 vacancy tax declarations filed by owners under the City’s Vacancy Tax By-Law No. 11674. Observers of the tax, which is unique in Canada, have…