Tax Alert Archives

Federal Court of Appeal confirms that payments of life insurance premiums can give rise to taxable benefits under subsections 15(1) and 246(1) of the ITA

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…

Prepared by: Sarah Faber

Sarah Faber is an associate practicing in the firm’s Toronto office. Her practice focuses on tax litigation and taxpayer representation at every level and also includes tax planning for businesses, individuals, not-for-profits and charities. She is currently working on a… more »

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CRA releases guidance on new trust reporting rules

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…

Prepared by: Tyler Berg

Tyler is an Associate working in the Vancouver office. Tyler attended the Peter A. Allard School of Law at the University of British Columbia, where he completed the Juris Doctor program and the Business Law Concentration.  He competed in the… more »

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Reminder: Vancouver Empty Homes Tax declaration due February 2

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…

Prepared by: Tyler Berg

Tyler is an Associate working in the Vancouver office. Tyler attended the Peter A. Allard School of Law at the University of British Columbia, where he completed the Juris Doctor program and the Business Law Concentration.  He competed in the… more »

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Artificial Intelligence (AI) in Federal Court

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…

Prepared by: Molly Martin

Molly Martin is an associate practicing in the firm’s Toronto office. Molly’s practice focuses on tax litigation and taxpayer representation at every level and also includes tax planning for businesses, individuals, not-for-profits and charities. Molly Martin writes on tax issues… more »

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Department of Finance releases draft regulation on enhanced GST rebates for new purpose-built rental housing

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,…

Prepared by: Adrian Zee

Adrian is an associate at the firm’s Vancouver office. Adrian’s practice focuses on Canadian commodity tax, including the Harmonized Sales Tax (HST), Goods and Services Tax (GST), provincial sales taxes, and realty taxes (including the B.C. Speculation and Vacancy Tax, City… more »

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CRA extends deadline for filing Underused Housing Tax (UHT) returns without interest or penalty

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…

Prepared by: Brittany Rossler

Brittany Rossler is an associate working out of the Toronto office of Thorsteinssons LLP. Brittany’s practice focuses on all aspects of tax litigation and dispute resolution. She has represented clients in appeals before the Tax Court of Canada, Federal Court… more »

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Canada Revenue Agency releases electronic mailing list for notifiable transactions

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…

Prepared by: Jonathan Longcroft

Jonathan is an associate at the firm’s Vancouver office. Jonathan is developing a varied tax law practice with an emphasis on corporate tax planning. Prior to joining Thorsteinssons, Jonathan worked at an international investment bank in New York where he… more »

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Constitutional challenge to the new reportable and notifiable transaction regimes as applying to legal professionals launched

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…

Prepared by: Antonio Alcantara Tangonan

Antonio Alcantara Tangonan is an associate working out of the Toronto office of Thorsteinssons LLP. Antonio is a Dual JD graduate from the University of Windsor and University of Detroit Mercy School of Law. In 2020, he competed in the… more »

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CRA releases new and revised mandatory disclosure forms

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”).

The revisions to the mandatory disclosure rules and

Prepared by: Sarah Faber , Justin Shoemaker

Sarah Faber is an associate practicing in the firm’s Toronto office. Her practice focuses on tax litigation and taxpayer representation at every level and also includes tax planning for businesses, individuals, not-for-profits and charities. She is currently working on a… more »

Justin is an associate at the firm’s Vancouver office. Justin’s practice focuses on all areas of income tax law, including corporate and international tax planning, flow-through share financing and mergers and acquisitions. more »

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Department of Finance releases draft legislation on Budget 2023 proposals and other notable tax measures

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…

Prepared by: Rebecca Loo

Rebecca Loo is a partner working out of the Toronto office of Thorsteinssons LLP. Rebecca’s practice focuses on Canadian commodity tax matters, including the Goods and Services Tax (GST), Harmonized Sales Tax (HST), and provincial sales taxes.  She has written… more »

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