Tax Alert Archives

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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Tax Court of Canada Issues Order Allowing Parties to be Served by E-mail

The Tax Court of Canada (“TCC”) recently issued a Practice Direction and Order (the “Order”) allowing parties to proceedings covered by the Tax Court of Canada Rules (General Procedure) to consent to be served by e-mail. The Order can be…

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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Department of Finance Extends Expanded Access to Local Lockdown Program and Canada Worker Lockdown Benefit

In a news release dated February 9, 2022, Canada’s Department of Finance announced its intention to extend enhanced key support programs to aid workers and businesses through ongoing public health restrictions.

Using regulatory authority provided in Bill C-2, the…

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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Department of Finance Publishes Significant Draft Legislative Proposals for Public Comment

On February 4, 2022, Canada’s Department of Finance published draft legislative proposals and related materials (the “Published Materials”) for public comment. The Published Materials relate to the proposed implementation of various tax measures, including those outlined in the Government of…

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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Tax Measures outlined in Minister of Finance Mandate Letter

On December 16, 2021, the Office of the Prime Minister issued a mandate letter to the Deputy Prime Minister and Minister of Finance, Chrystia Freeland. The letter asked that steps be taken to establish or strengthen programs addressing public…

Prepared by: Chris Canning , Alexei Paish

Chris is a partner practicing in the firm’s Vancouver office. Chris’s practice focuses on tax litigation and taxpayer representation. He represents taxpayers in all manner of tax disputes, including income tax and GST/HST auditsmore »

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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