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. …
The recently enacted “flipped property” rules in the Income Tax Act (Canada) (the “Act”) have wide ranging implications. Several tax practitioners have written about the problematic nature of the rules (see, for example: Evan Crocker and Kenneth Keung, “Related-Party Transfers…
On July 24, 2023, the Canada Revenue Agency (CRA) released the new and revised forms applicable to the enhanced mandatory disclosure rules under the Income Tax Act (Canada) (the “Act”).
On August 4, 2023, the Department of Finance released draft legislative proposals relating to certain measures that were announced as part of the 2023 federal budget (“Budget 2023”) as well as other previously-announced measures. Included is draft legislation on…
When is an allocation of costs amongst supplies “fair and reasonable” for calculating input tax credits (“ITCs”)? In Marine Atlantic Inc. v The King (2023 TCC 95), the Tax Court confirmed that a “fair and reasonable” allocation:
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The CRA has published two separate documents relating to the new and expanded mandatory disclosure rules, which became law on June 22, 2023. For discussion of those rules, see our previous tax alert and blog post.
The first…