Tax Alert Archives

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 his clients’ personal and business affairs. Alexei’s advisory work relates primary to succession / estate… 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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Finance postpones proposed effective date for enhanced trust reporting, reportable transaction, and notifiable transaction rules

On November 4, 2022, Bill C-32 (44-1) was tabled in the House of Commons. Among other things, that Bill contains the latest version of the proposed enhanced trust reporting rules and stipulates that they would be effective for trusts’…

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 Sets Date for Release of Fall Economic Statement 2022

The Federal Government has announced that the Fall Economic Statement 2022 will be presented in the House of Commons on November 3, 2022 at approximately 4:00 p.m. ET.

The Federal Government’s 2022 Budget stated that the Fall Economic…

Prepared by: Rebecca Loo , Brendan Forrest

Rebecca Loo is a partner working out of the Toronto office of Thorsteinssons LLP. Rebecca’s practice focuses on Canadian commodity tax matters, including the Goods and Services Tax (GST), Harmonized Sales Tax (HST), and provincial sales taxes.  She has written… more »

Brendan Forrest is an associate working out of the Toronto office of Thorsteinssons LLP. Brendan’s practice focuses on corporate tax advisory and planning services. Brendan earned his Bachelor of Arts (Honours) from St. Michael’s College at the University of Toronto… more »

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Ontario Ministry of Finance Increases Non-Resident Speculation Tax Rate

Effective October 25, 2022, the government of Ontario has increased the Non-Resident Speculation Tax (“NRST”) rate to 25 percent.

The increase follows changes made to the tax earlier in 2022. Introduced in April 2017, the NRST initially applied a…

Prepared by: Rebecca Loo , Brendan Forrest

Rebecca Loo is a partner working out of the Toronto office of Thorsteinssons LLP. Rebecca’s practice focuses on Canadian commodity tax matters, including the Goods and Services Tax (GST), Harmonized Sales Tax (HST), and provincial sales taxes.  She has written… more »

Brendan Forrest is an associate working out of the Toronto office of Thorsteinssons LLP. Brendan’s practice focuses on corporate tax advisory and planning services. Brendan earned his Bachelor of Arts (Honours) from St. Michael’s College at the University of Toronto… more »

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Canada Revenue Agency comments on relief from double tax under Articles XIII(7) and XXIV(2) of the Canada-U.S. Tax Treaty on deemed disposition of U.S. real estate

In Canada Revenue Agency (“CRA”) Views document number 2021-0922301I7, the CRA considered a Canadian-resident trust deemed to dispose (for Canadian income tax purposes) of U.S. real property on its 21-year anniversary. The CRA was asked whether: (a) the trust could…

Prepared by: Brendan Forrest

Brendan Forrest is an associate working out of the Toronto office of Thorsteinssons LLP. Brendan’s practice focuses on corporate tax advisory and planning services. Brendan earned his Bachelor of Arts (Honours) from St. Michael’s College at the University of Toronto… more »

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