Tax Alert Archives

CRA publishes detailed guidance documents relating to new mandatory disclosure rules

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…

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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New / expanded mandatory disclosure rules become law

On June 22, 2023, Bill C-47 – An Act to implement certain provisions of the budgets tabled in Parliament on March 28, 2023 received Royal Assent. As a consequence, new or expanded mandatory reporting rules for certain “reportable” or “notifiable”…

Prepared by: Joseph Eid

Joe is an associate at the firm’s Toronto office. Joe’s practice focuses on Canadian tax planning for individuals, trusts and corporations. Before joining Thorsteinssons, Joe completed a judicial clerkship at the Tax Court of Canada and was Legal Counsel at… more »

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Retroactive legislation to reverse recent court decision on BC provincial sales tax and cloud computing

On June 20, 2023, the Province of British Columbia (the “Province”) released a Provincial Sales Tax (PST) Notice to providers and purchasers of cloud software and services (the “Notice”). The Notice came in response to the B.C. Supreme Court…

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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An amalgamation can disrupt Bill C-208 intergenerational planning

The amendments to section 84.1 implemented by Bill C-208 (43rd Parliament, 2nd session) permit intergenerational share transfers to corporations controlled by a child or grandchild to be executed on a tax-efficient basis. If certain conditions are met, parents and grandparents…

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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SCC dismisses taxpayer’s appeal in Deans Knight (2023 SCC 16)

Today, by a 7:1 majority, the Supreme Court of Canada dismissed the appeal of Deans Knight Income Corporation (“Deans Knight”) from a 2021 decision of the Federal Court of Appeal that upheld the application of the general anti-avoidance…

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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Federal government narrows the scope of the Foreign Home Buyers Ban

On March 27, 2023, the Federal government announced important changes to the Foreign Home Buyers Ban, which came into effect on January 1, 2023. We previously published a detailed tax alert explaining the Foreign Home Buyers Ban. The new…

Prepared by: Morgan Watchorn

Morgan Watchorn is an associate working out of the Vancouver office of Thorsteinssons LLP. Morgan earned her Juris Doctor from Thompson Rivers University. While in law school, she competed in the Bowman National Tax Moot and worked as a teaching… more »

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Budget 2023 scheduled for March 28

Finance Minister Chrystia Freeland announced today that the 2023 Federal Budget will be presented on March 28, 2023. Although the federal government’s 2022 Fall Economic Statement signalled its intention to proceed with a number of previously announced tax measures, it…

Prepared by: Milan Vukovic

Milan is a partner practising in the firm’s Toronto office. Milan frequently advises on personal, corporate and trust planning, with a particular focus on high-net-worth professionals, owner-managers and their businesses. His practice encompasses all aspects of domestic Canadian tax law,… more »

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Reminder: January 30 deadline for paying interest on prescribed rate loans or indebtedness

A loan or indebtedness which meets the following statutory requirements is generally referred to as a “prescribed rate loan”:

(a) interest is charged on the loan or indebtedness at a rate equal to or greater than the lesser…

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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Canadian foreign home buyers ban coming into effect

The Prohibition on the Purchase of Residential Property by Non-Canadians Act (the “Act”) enters into force this Sunday (January 1, 2023). As supplemented by detailed regulations (the “Regulations”), the Act prohibits any “non-Canadian” from purchasing, directly or indirectly,…

Prepared by: Alexander Demner, TEP , Alexei Paish

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 »

Alexei Paish is an associate practicing in the firm’s Vancouver office. Alexei maintains a broad tax practice with a view to achieving tax efficiency across all of his clients’ personal and business affairs. Alexei focusses on advising in respect of… more »

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Finance publishes revised excessive interest and financing expenses limitation (EIFEL) rules (with broader “excluded entity” definition)

On November 3, 2022, the Department of Finance released revised draft legislation proposing to implement the “excessive interest and financing expenses limitation” (EIFEL) rules first announced in Budget 2021. Initial draft legislation was released on February 4, 2022 and…

Prepared by: Morgan Watchorn

Morgan Watchorn is an associate working out of the Vancouver office of Thorsteinssons LLP. Morgan earned her Juris Doctor from Thompson Rivers University. While in law school, she competed in the Bowman National Tax Moot and worked as a teaching… more »

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