Tax Alert Archives June 2021

Documents requested pursuant to a requirement for information under s. 288(1) of the Excise Tax Act (Canada) need not be proportional to matter at issue

In Canada (National Revenue) v. 2276230 Ontario, 2021 FC 242, the Federal Court granted a compliance order to the CRA citing the Federal Court of Appeal’s decision in Canada (National Revenue) v. Cameco Corporation, 2019 FCA 67, for…

Prepared by: Leonard Gilbert , Chris Marta

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 »

Chris Marta is an associate practising in the firm’s Vancouver office. Chris Marta’s practice focuses on domestic and international tax planning for individuals, trusts and corporations. He also represents taxpayers in their disputes with the Canada Revenue Agency. Prior to… more »

Share

Senate Passes Significant Tax Bill Aimed at Facilitating Intergenerational Business Transfers

On June 22, 2021, the Senate passed Bill C-208 (following its previous passage in the House of Commons). A Private Members’ Bill, Bill C-208 is aimed at facilitating intergenerational business transfers and follows similar Bills introduced by various political parties…

Prepared by: Alexander Demner

Alexander is a partner practicing in the firm’s Vancouver office. Alexander’s practice covers several areas of taxation, including estate planning, pre-sale and divestiture structuring, owner-manager remuneration, taxpayer representation, and tax litigation. Alexander routinely advises on and implements reorganizations for individuals,… more »

Share

CRA Updates Guidance on Competent Authority Assistance

On June 1, 2021, the CRA published Information Circular IC71-17R6 (“IC71-17R6”), which provides guidance on obtaining assistance under a mutual agreement procedure (“MAP”) article of a Canadian tax convention. New IC71-17R6 replaces and cancels its predecessor IC71-17R5 dated January…

Prepared by: Leonard Gilbert , Chris Marta

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 »

Chris Marta is an associate practising in the firm’s Vancouver office. Chris Marta’s practice focuses on domestic and international tax planning for individuals, trusts and corporations. He also represents taxpayers in their disputes with the Canada Revenue Agency. Prior to… more »

Share

COVID-19 Tax Update: Tax Court Announces Further Cancellations

On June 1, 2021, the Tax Court of Canada released a further Notice to the Public and the Profession regarding its upcoming hearing schedule.

Previously, the Court issued a Notice cancelling all in-person hearings up to July 16, 2021 as a…

Prepared by: Rebecca Potter

Rebecca Potter is a partner practicing in the firm’s Toronto office. Rebecca’s practice focuses on all aspects of taxpayer representation and tax litigation and also includes tax planning for charities and not-for-profits. She has appeared before the Tax Court of… more »

Share