Tax Alert Archives

Taxpayer sentenced to jail for continued non-compliance with court orders requiring him to produce records to the CRA

In a recent Federal Court case, the court sentenced a taxpayer for contempt of court for refusing to comply with a court order requiring the production of records to the CRA. The court imposed a fine of $6,000 and again…

Prepared by: Jennifer Flood

Jennifer Flood is an associate practicing in the firm’s Vancouver office. Jennifer’s practice focuses on taxpayer representation and tax litigation (including civil and criminal matters), and also includes personal and corporate tax planning. Prior to joining Thorsteinssons, she worked as… more »

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Federal Court of Appeal Rules on GAAR Again

In Fiducie financière Satoma c. Canada, 2018 CAF 74, the Federal Court of Appeal ruled on the General Anti-Avoidance Rule (the “GAAR”) again this year (see our previous Alert re: Oxford Properties). In upholding the Tax Court of Canada’s…

Prepared by: Josh Kumar

Josh’s practice focuses on tax litigation and dispute resolution with the Canada Revenue Agency and Department of Justice, as well as domestic and international tax planning for individuals, trusts and corporations, including estate planning, reorganizations and business structuring. Josh clerked… more »

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Deadline Approaching to Dispute Vancouver Vacancy Tax Notices

Monday, April 16, 2018, is the deadline to submit notices of complaint to dispute vacancy tax notices issued by the City of Vancouver. Any registered owner who received a vacancy tax notice could potentially submit a complaint, even if they…

Prepared by: Noah Sarna

Noah is a partner practising in the firm’s Toronto and Vancouver offices. Noah’s practice focuses on all aspects of commodity tax, including Goods and Services Tax/Harmonized Sales Tax, provincial sales taxes, property or land transfer taxes and municipal taxation as… more »

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Federal Court of Appeal Rules in GAAR Case

In Canada v. Oxford Properties Group Inc., 2018 FCA 30, the Federal Court of Appeal allowed in part the Crown’s appeal and referred the reassessment of the taxpayer back to the Minister of National Revenue for reconsideration.

The taxpayer…

Prepared by: Jenna Himelfarb

Jenna is an associate at the Toronto office of Thorsteinssons. Jenna advises clients on the tax aspects of a wide variety of matters, including corporate reorganizations and restructurings, mergers and acquisitions and cross-border structures. She also practises in the areas… more »

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Revised Income Splitting Rules and Guidance

The Department of Finance has released revised draft legislation and background information on its proposals to prevent income splitting. The documents can be accessed here. This release follows on the Department’s private corporation consultation paper of July 18, 2017,…

Prepared by: Kyle Lamothe

Kyle is a partner practicing in the firm’s Toronto office. Kyle’s practice focuses on personal, corporate and trust planning for high net worth families, professionals, and owner-managers and their businesses, both domestic and international. He advises on corporate reorganizations, purchases… more »

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OECD approves the 2017 update to the OECD Model Tax Convention

On November 21, 2017, the OECD Council approved the contents of the 2017 Update to the OECD Model Tax Convention.

The 2017 Update primarily comprises changes to the OECD Model Tax Convention and related commentary that were developed through the…

Prepared by: Ian Humphries

Ian Humphries is an Associate working out of the Vancouver office of Thorsteinssons LLP. Ian joined Thorsteinssons after articling and practicing securities law at a national law firm. Prior to law school, Ian worked as an investment banker in the… more »

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Parliamentary Budget Officer (PBO) Releases Report on Proposed Changes to Passive Investment Income

On November 23, 2017, the PBO released its analysis estimating the potential fiscal magnitude of changes to passive income taxation based on Finance Canada’s July 18, 2017, consultation document.

The PBO’s analysis also factors in the October 18, 2017 Department…

Prepared by: Ian Humphries

Ian Humphries is an Associate working out of the Vancouver office of Thorsteinssons LLP. Ian joined Thorsteinssons after articling and practicing securities law at a national law firm. Prior to law school, Ian worked as an investment banker in the… more »

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Auditor General of Canada Releases 2017 Fall Report

On November 21, 2017, the Auditor General released its Fall Report containing the results of 6 audits completed since the summer, including an audit of the timeliness and accuracy of information provided by Canada Revenue Agency Call centres.

Some key…

Prepared by: Ian Humphries

Ian Humphries is an Associate working out of the Vancouver office of Thorsteinssons LLP. Ian joined Thorsteinssons after articling and practicing securities law at a national law firm. Prior to law school, Ian worked as an investment banker in the… more »

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Government of Canada Announces Consultation on Proposed Excise Duty Framework for Cannabis Products

On November 10, 2017, the Department of Finance released proposed legislation concerning an excise duty framework for cannabis products for comment. The proposed duty would apply to all cannabis products available for legal sale, including fresh and dried cannabis, cannabis…

Prepared by: Ian Humphries

Ian Humphries is an Associate working out of the Vancouver office of Thorsteinssons LLP. Ian joined Thorsteinssons after articling and practicing securities law at a national law firm. Prior to law school, Ian worked as an investment banker in the… more »

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Finance News Release: “Government moves to Reduce Small Business Tax Rate and Support Fairness for the Middle Class”

Federal small business rate lowered to 10% on Jan. 1, 2018; 9% on Jan. 1, 2019. Proposed capital gains exemption limitation changes abandoned. Proposed income sprinkling measures to be simplified.

Link: http://www.fin.gc.ca/n17/17-097-eng.asp

Prepared by: Leonard Gilbert

Leonard graduated from the University of Toronto, Faculty of Law (J.D. 2015) and is currently an associate practicing in the firm’s Toronto office. He previously performed extensively as a concert pianist and attended the Jacobs School of Music at Indiana… more »

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