Tax Alert Archives

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 is a litigation associate in the Vancouver office of Thorsteinssons LLP. Morgan represents clients in all matters of tax disputes. She assists clients being audited by the Canada Revenue Agency and represents clients in disputes at the Appeals Division… 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 Thorsteinssons LLP in Vancouver. Jonathan maintains a varied tax law practice with an emphasis on corporate and international tax planning. Prior to joining Thorsteinssons, Jonathan worked at an international investment bank in New York where… 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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Supreme Court of Canada allows Crown’s appeal in Collins Family Trust rescission case

The Supreme Court of Canada (SCC) has allowed the Attorney General of Canada’s appeal in Canada (Attorney General) v. Collins Family Trust, 2022 SCC 26. In doing so, a majority of the SCC held that taxpayers may not resort to…

Prepared by: Alexei Paish

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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Supreme Court of Canada Grants Leave to Appeal in Québec Stock Options Case

The Supreme Court of Canada (“SCC”) has granted the application for leave to appeal in Agence du revenue du Québec c. Des Groseillers, 2021 QCCA 906.

Des Groseillers concerns the tax treatment of donated employee stock options under…

Prepared by: Alexei Paish

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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Federal Court of Appeal Refuses to Compel the Payment of Claimed GST/HST Refunds

The jurisdictional boundaries between the Tax Court of Canada and Federal Court over taxation matters has often been a trap for taxpayers. In Iris Technologies Inc. v. Canada (National Revenue), 2022 FCA 39 (“Iris Technologies”), the Federal Court of Appeal…

Prepared by: Alexei Paish

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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