Tax Alert Archives

COVID-19 Tax Update: Finance Details Extension of CEWS / CERS Programs to June 2021

On March 3, 2021, further to statements in the Fall Economic Statement the Government of Canada confirmed its intention to further extend the Canada Emergency Wage Subsidy (CEWS) and Canada Emergency Rent Subsidy and Lockdown Support (CERS) programs through June…

Prepared by: Nicholas McIsaac

Nicholas is an associate at the Toronto office of Thorsteinssons. Nicholas’ practice focuses on corporate and international tax planning, regularly advising Canadian and foreign-based multi-national groups on a variety of matters, including financing, mergers and acquisitions, restructurings and natural resource… more »

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Ontario Court of Appeal unpersuaded by principle that governments have the right to legislate “illogically”

In Stonehouse Group Inc. v. Ontario (Minister of Finance), 2021 ONCA 10, a taxpayer was successful in its dispute with the Ministry of Finance. As a result, a refund of the reassessed taxes was paid. The Minister of Finance…

Prepared by: Leonard Gilbert , Morgan Watchorn

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 »

Morgan Watchorn is an associate working out of the Vancouver office of Thorsteinssons LLP. During law school, Morgan worked as a teaching assistant in the Faculty of Law and served as a representative on the Faculty of Law Equity Committee.… more »

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CRA not providing relief where COVID-related delays create difficulties in meeting deadline for s. 164(6) loss carrybacks within estate’s first taxation year

In CRA Technical Interpretation 2020-0865071E5, the CRA was asked whether it would allow more time for the application of s. 164(6) of the Income Tax Act (Canada) where COVID has resulted in delays regarding the administration of an estate.  The…

Prepared by: Leonard Gilbert , Morgan Watchorn

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 »

Morgan Watchorn is an associate working out of the Vancouver office of Thorsteinssons LLP. During law school, Morgan worked as a teaching assistant in the Faculty of Law and served as a representative on the Faculty of Law Equity Committee.… more »

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Tax Court of Canada provides clarity on timing of allocating costs between different taxation years

In Yorkwest Plumbing Supply Inc. v. The Queen, 2020 TCC 122, due to a switch in the appellant’s accounting system the cost of inventory was not properly allocated against the cost of sales. The appellant attempted to overstate its…

Prepared by: Leonard Gilbert , Morgan Watchorn

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 »

Morgan Watchorn is an associate working out of the Vancouver office of Thorsteinssons LLP. During law school, Morgan worked as a teaching assistant in the Faculty of Law and served as a representative on the Faculty of Law Equity Committee.… more »

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Federal Court of Appeal finds that a corporation must be represented by counsel in tax appeals

In Canada v. BCS Group Business Services Inc., 2020 FCA 205, the Federal Court of Appeal held that a corporation cannot not appear “in person” and must be represented by counsel in appeals under the Tax Court’s General Procedure.…

Prepared by: Leonard Gilbert , Morgan Watchorn

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 »

Morgan Watchorn is an associate working out of the Vancouver office of Thorsteinssons LLP. During law school, Morgan worked as a teaching assistant in the Faculty of Law and served as a representative on the Faculty of Law Equity Committee.… more »

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COVID-19 Tax Update: Updates from the Tax Court

On February 9, 2021, Chief Justice Eugene Rossiter of the Tax Court of Canada held a webinar to update the public on the Court’s current status and outlook as a consequence of the COVID-19 pandemic.

The Tax Court previously announced…

Prepared by: Tyler Berg

Tyler is an Associate working in the Vancouver office. During his law degree, Tyler participated in the Law Students’ Legal Advice Program and the UBC Law Review, and played intramural ice hockey for the UBC Law Legal Eagles. Tyler also… more »

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REMINDER: Deadline to Apply for or Amend Initial CEWS Applications Fast Approaching

Employers are reminded that January 31, 2021 is the deadline to file a CEWS application for the initial qualifying periods or to amend any elections previously made in respect of those periods.

As background, to qualify for the CEWS an…

Prepared by: Alexander Demner , Ian Humphries

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 »

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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COVID-19 Tax Update: B.C. Extends Limitation Period to File Appeals to the Minister of Finance

In light of the hardships posed by COVID-19, the BC Ministry of Finance has extended the time limits for filing appeals to the Minister for appeals due on or after March 18, 2020 but before January 5, 2021, until…

Prepared by: Zheting Su

Zheting is an associate at the firm’s Vancouver office. Zheting’s practice focuses on all aspects of transactional/commodity taxes, including the Harmonized Sales Tax (HST), Goods and Services Tax (GST), First Nations GST, provincial sales taxes, realty taxes (such as land/property… more »

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COVID-19 Tax Update: Tax Court of Canada cancels in-person judicial sittings through January 15, 2021

On November 26, 2020, the Tax Court of Canada cancelled all in-person judicial sittings scheduled between November 30, 2020 and January 15, 2021 (other than select sittings underway which conclude the week of November 30th). All parties affected by this…

Prepared by: Morgan Watchorn

Morgan Watchorn is an associate working out of the Vancouver office of Thorsteinssons LLP. During law school, Morgan worked as a teaching assistant in the Faculty of Law and served as a representative on the Faculty of Law Equity Committee.… more »

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COVID-19 Tax Update: Finance proposes further extension and revisions to CEWS program

On November 2, 2020, Parliament tabled Bill C-9 which, among other things, proposes to further extend and revise the Canada Emergency Wage Subsidy (CEWS) program. The proposals are in addition to the extensive CEWS revisions enacted on July 27, 2020;…

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 »

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