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…
On December 20, 2023, the Federal Court released a Notice to the Parties and the Profession on the use of Artificial Intelligence (AI). The Notice applies to all documents that are either submitted to the Court or prepared for…
On December 14, 2023, the Department of Finance released draft regulations (the “Regulations”) intended to clarify the enhanced 100% GST rebate for new purpose-built rental housing. The Regulations will be deemed to have come into force on September 14,…
A recent decision from the British Columbia Supreme Court (“BCSC”), AF2G Investments Inc. v. Minister of Finance (BC), 2023 BCSC 2133, provided guidance on when a communication constitutes an objection under section 19 of the Property Transfer Tax Act,…
Earlier this week, the Supreme Court of Canada heard two tax appeals that may help clarify the jurisdictional boundaries between the Tax Court of Canada and Federal Court: Dow Chemical Canada ULC v His Majesty the King (SCC File No.…
The Canada Revenue Agency has further extended the deadline for owners affected by the Underused Housing Tax (“UHT”) to file their returns for the 2022 taxation year, without being charged interest or penalties, to April 30, 2024. While UHT…
The CRA recently released an electronic mailing list primarily to notify subscribers when a new notifiable transaction has been designated by the Minister of National Revenue. The subscription webpage also indicates that subscribers to the electronic mailing list may…
On June 22, 2023, Bill C-47 received Royal Assent, bringing into force new or expanded mandatory reporting rules for certain “reportable” or “notifiable” transactions (the “Mandatory Disclosure Rules”). The Mandatory Disclosure Rules require taxpayers, promoters and certain advisors (including legal…
Yesterday, the Department of Finance announced GST relief for new residential rental construction. In addition to signaling a reduction in the cost of supplying new rental homes, the measure potentially reduces or eliminates a major source of friction between…
Context: As part of the avalanche of new draft legislation, the Department of Finance has released revised excessive interest and financing expenses limitation (EIFEL) rules. The attached Excel is a high-level and technical summary of the new EIFEL regime. …