Tax Alert Archives

CRA to transition to online delivery of business correspondence

The Canada Revenue Agency (CRA) recently announced that, starting in the spring of 2025, it will transition to using the CRA’s online portal for businesses (My Business Account) as the default method of sending correspondence to businesses, instead of…

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 »

Share

CRA publishes webpage with examples of allegedly GAAR-able transactions

On December 20, 2024, the CRA published its views on the general anti-avoidance rule (GAAR) in a new webpage. The webpage contains some general comments by the CRA regarding the GAAR, examples of when the CRA would apply the…

Prepared by: Patrick R. Murray

Patrick attended the Peter A. Allard School of Law at the University of British Columbia, where he completed the Master of Laws in Taxation program while earning his National Committee on Accreditation certificate. Patrick is also a JD graduate from… more »

Share

CRA proactively announces no bare trust reporting required for 2024

Yesterday, the CRA announced it will not require bare trusts to file a T3 Income Tax and Information Return (including Schedule 15 Beneficial Ownership Information of a Trust) for their 2024 taxation year, unless the CRA directly requests such…

Prepared by: Cadie Yiu

Cadie Yiu is an associate practicing in the firm’s Toronto office. Cadie advises on all aspects of domestic and international tax planning, corporate reorganizations, mergers and acquisitions, and trust and estate planning for individuals and families. She also advises clients… more »

Share

Draft legislation to exempt tenants from deducting and withholding tax on residential rent paid to non-resident landlords

Subsection 215(1) of the Income Tax Act (the “Act”) imposes on Canadian tenants the obligation to withhold and remit Part XIII tax on residential rent paid to non-resident landlords. The applicable tax rate is 25% of the gross rent paid,…

Prepared by: Vivian Esper

Vivian is an is a partner working out of the Vancouver office of Thorsteinssons LLP. Vivian’s practice focuses on tax dispute resolution with the Canada Revenue Agency and Tax Court of Canada.  Her practice also includes tax planning involving individuals,… more »

Share

Enhanced GST rental rebate: CRA opines that construction begins on excavation

Yesterday, the Canada Revenue Agency (“CRA”) announced that, in its view, the construction of purpose-built rental housing (“PBRH”) for purposes of the PBRH rebate under the Excise Tax Act is generally “considered to begin at the time the excavation…

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 »

Share

DAC Investment – Tax Court rules that “non-CCPC planning” is not abusive under GAAR

Yesterday, the Tax Court of Canada released its decision in DAC Investment Holdings Inc. v R. Led by Matthew Williams, Florence Sauve, and Brittany Rossler, the decision represents a major win for taxpayers across the country.

In…

Prepared by: Katherine Neil

Katherine Neil is an associate practicing in the Vancouver office. Katherine obtained her Juris Doctor degree from the Schulich School of Law at Dalhousie University in 2022. After graduating from law school, she articled at a large, full-service firm based… more »

Share

“B.C. home flipping tax” bill tabled in B.C. legislature

The B.C. government tabled legislation yesterday which would introduce its proposed “home flipping tax”. First announced in the province’s 2024 budget (and discussed in greater detail in our previous blog post), the draft legislation was contained in Bill

Prepared by: Jonathan Longcroft

Jonathan is an associate at Thorsteinssons LLP in Vancouver. Jonathan maintains a varied tax law practice with an emphasis on corporate and international tax planning. Prior to joining Thorsteinssons, Jonathan worked at an international investment bank in New York where… more »

Share

Toronto increasing Vacant Home Tax audits

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…

Prepared by: Morgan Watchorn

Morgan is a litigation associate in the Vancouver office of Thorsteinssons LLP. Morgan represents clients in all matters of tax disputes. She assists clients being audited by the Canada Revenue Agency and represents clients in disputes at the Appeals Division… more »

Share