Tax Alert Archives

The CRA releases a list of tax tips for students

On February 11, 2020, the CRA published a list of tax tips aimed at providing students and taxpayers with no or almost no income with useful reminders on benefits and credits they may qualify for.

Prepared by: Julia Ji

Julia Ji is an associate practising in the firm’s Toronto office. Julia’s practice includes corporate tax advisory, tax planning, business structuring and tax litigation. Prior to joining Thorsteinssons, Julia was a certified digital project manager specializing in enterprise information architecture… more »

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B.C. Government Releases 2020 Budget

B.C. government releases Budget 2020.

Prepared by: Julia Ji

Julia Ji is an associate practising in the firm’s Toronto office. Julia’s practice includes corporate tax advisory, tax planning, business structuring and tax litigation. Prior to joining Thorsteinssons, Julia was a certified digital project manager specializing in enterprise information architecture… more »

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Tax Court of Canada issues $300,000 costs award in favour of taxpayer

In Univar Holdco Canada ULC v The Queen, 2020 TCC 15, the Tax Court awarded costs of over $300,000 in favour of the taxpayer, representing approximately 50% of the taxpayer’s legal fees for the appeal, plus disbursements. In light of…

Prepared by: Julia Ji

Julia Ji is an associate practising in the firm’s Toronto office. Julia’s practice includes corporate tax advisory, tax planning, business structuring and tax litigation. Prior to joining Thorsteinssons, Julia was a certified digital project manager specializing in enterprise information architecture… more »

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Taxpayer successful on s. 160 assessment

In reaching the decision, the Tax Court of Canada considered whether the parties to the transaction attempted to place the CRA in “any different position whatsoever as a result of the transfer”. The Court found that they did not.…

Prepared by: Julia Ji

Julia Ji is an associate practising in the firm’s Toronto office. Julia’s practice includes corporate tax advisory, tax planning, business structuring and tax litigation. Prior to joining Thorsteinssons, Julia was a certified digital project manager specializing in enterprise information architecture… more »

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Reminder: Complete Empty Homes Tax Declaration by February 4, 2020

Registered owners of residential property in Vancouver are reminded to complete their 2019 property status declarations by February 4, 2020.  Owners should have already received reminder notices from the City of Vancouver.  Failure to make the declaration will result in…

Prepared by: Alvin Lun

Alvin’s practice focuses on domestic and international tax planning for individuals, trusts, and corporations, as well as representing taxpayers in their disputes with the Canada Revenue Agency. He is fluent in Cantonese and Mandarin Chinese. Prior to joining Thorsteinssons, Alvin… more »

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Reminder: Pay the interest on prescribed-rate loans or indebtedness by January 30

Prescribed-rate loans or indebtedness generally refer to loans or indebtedness that meet the following statutory requirements to qualify for an exception to certain attribution rules in the Income Tax Act (Canada):

  1. interest is charged on the loan or indebtedness

Prepared by: Alvin Lun

Alvin’s practice focuses on domestic and international tax planning for individuals, trusts, and corporations, as well as representing taxpayers in their disputes with the Canada Revenue Agency. He is fluent in Cantonese and Mandarin Chinese. Prior to joining Thorsteinssons, Alvin… more »

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Speculation and Vacancy Tax: Rental Restriction Exemption Extended Through to 2021

On December 23, 2019, the BC Government issued Order in Council No. 723 (the “Order”).  Among other things, the Order establishes the Exemptions from Tax Regulation (the “Regulation”) and amends the Regulation to extend the exemption for properties subject to…

Prepared by: Alvin Lun

Alvin’s practice focuses on domestic and international tax planning for individuals, trusts, and corporations, as well as representing taxpayers in their disputes with the Canada Revenue Agency. He is fluent in Cantonese and Mandarin Chinese. Prior to joining Thorsteinssons, Alvin… more »

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Update on Proposed Amendments to Stock Option Rules

On June 17, 2019, the federal government tabled a notice of ways and means motion proposing legislative amendments to the stock option regime. Consistent with the intention announced in the 2019 federal budget, the draft legislation imposes a $200,000 annual…

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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Federal Court Rejects Charter Challenge of FACTA Related Provisions of the Income Tax Act

On July 22, 2019, the Federal Court released its reasons for judgement in rejecting a constitutional challenge of sections 263-269 of the Income Tax Act (Canada) (the “ITA”). The full reasons can be found at 2019 FC 960 (“Deegan”).…

Prepared by: Ian Humphries

Ian Humphries is a partner 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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163(1) Repeated Failure to Report Penalty Upheld

In the recent decision in Polubiec (2019 TCC 146), the Tax Court of Canada upheld the assessment of approximately $140,000 in penalties under the repeated failure to report income penalty under s. 163(1) of the Income Tax Act (Canada). In…

Prepared by: Ian Humphries

Ian Humphries is a partner 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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