Yesterday, the Canada Revenue Agency (“CRA”) announced that, in its view, the construction of purpose-built rental housing (“PBRH”) for purposes of the PBRH rebate under the Excise Tax Act is generally “considered to begin at the time the excavation…
Yesterday, the Tax Court of Canada released its decision in DAC Investment Holdings Inc. v R. Led by Matthew Williams, Florence Sauve, and Brittany Rossler, the decision represents a major win for taxpayers across the country.
In…
Yesterday (April 16, 2024), the Department of Finance Canada published its 2024 federal budget (“Budget 2024”). Several major tax proposals were announced. This blog post briefly outlines those relating to income tax.
1. Increased Capital Gains Inclusion Rate …
Filing a notice of objection is the first step a taxpayer must take to dispute an assessment or reassessment issued by the Minister of National Revenue (the “Minister”). Failure to follow the proper procedural rules for filing an objection can…
The B.C. government tabled legislation yesterday which would introduce its proposed “home flipping tax”. First announced in the province’s 2024 budget (and discussed in greater detail in our previous blog post), the draft legislation was contained in Bill…
BC announced several proposed tax measures in its 2024 budget (released on February 22, 2024). Included in the long list of proposed changes – the more notable of which were summarized in our recent Tax Alert – are…
The Canada Revenue Agency (“CRA”) announced today that – “in recognition that the new reporting requirements for bare trusts have had an unintended impact on Canadians” – it will not require bare trusts to file a T3 income tax…
The City of Toronto appears to be ramping up its Vacant Home Tax (VHT) audit program. While historically there has been minimal compliance or enforcement activity undertaken, as of March 4, 2024 a total of 466 properties were under audit…
The Federal Court of Appeal (the “FCA”) recently released its decision in 3295940 Canada Inc v His Majesty The King, 2024 FCA 42. This decision is a welcome development in the jurisprudence regarding the application of the General Anti-Avoidance…
Tax and industry professionals have been waiting for the Federal Court of Appeal (the “FCA”) to issue its decision in Glencore Canada Corporation v R for several months. The decision under appeal (2021 TCC 63) sparked many discussions, and the…