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 Standard…
Canadian taxpayers have a statutory right to information under the government’s control, subject only to limited and specific exceptions (Access to Information Act, s. 2(1)). One such exception is for information protected by solicitor-client privilege. In The Information Commissioner…
In a well-reasoned technical interpretation (2014-0525501E5, just released), the Canada Revenue Agency (CRA) concluded that payments by Canadian companies (Usercos) to UK and US resident companies (Ownercos) for the right to use customer lists owned by the Ownercos are exempt…
In a rather bold move, the taxpayer in Coast Capital Savings Credit Union v. Canada (2015 TCC 195) claimed that it was the victim of a “sham” and sought to amend its notice of appeal on a motion before the…
This blog was co-authored by Simon Thang and Rosemary Anderson.
Time is running out to file an important Goods and Services Tax (GST/HST) election form that, until recently, was not required to be filed.
Specifically, Canadian corporations and partnerships that…
Subsection 104(13.4) of the Income Tax Act (the “Act”) will come into effect on January 1, 2016. If not corrected, this provision will have a catastrophic and devastating effect on many estate plans involving alter ego trusts, joint spousal and…
The recent case of Boroumand v. The Queen 2015 TCC 239 neatly illustrates just how challenging a forum the Tax Court can be for certain appellants. The facts of the case are unremarkable and common enough: the appellant was brought…