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…
On February 22, 2024, the British Columbia Minister of Finance tabled the province’s 2024 budget.
The 2024 budget contains a number of notable tax measures, including the following:
Provincial Anti-Flipping Tax
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In Gestion M.-A. Roy Inc. c Canada (2024 FCA 16), the Federal Court of Appeal agreed with the Tax Court that the corporate holders of two life insurance policies received taxable benefits where the premiums of both policies were paid…
The CRA has released an FAQ page regarding the new reporting rules in respect of trusts for taxation years ending on or after December 31, 2023. As stated by the CRA, “many trusts that did not previously have to…
Vancouver homeowners are reminded to file their Empty Homes Tax declaration for the 2023 year by February 2, 2024. Failure to file the declaration by the deadline will result in the subject property being deemed to have been vacant…
I. INTRODUCTION
The Department of Finance first publicly announced an intention to modify the general anti-avoidance rule (the “GAAR”), found in section 245 of the Income Tax Act (Canada) (the “Act”), on November 30, 2020. This intention most recently came…