Tax Alert Archives

Land Owner Transparency Act (LOTA) – Deadline for Pre-Existing Owners to File Transparency Reports Extended By One Year

The B.C. Government has extended by one year the deadline for pre-existing owners of a registered interest in land that are reporting bodies to file a transparency report with the Land Owner Transparency Registry (the “Registry”). Prior to the extension,…

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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New Ontario Business Registry Launches Online

The Ontario Ministry of Government and Consumer Services launched its much-anticipated Ontario Business Registry online today. Organizations that are incorporated, registered or licensed to carry on business in Ontario can now directly access over 90 services 24/7 all-year-round, and will be…

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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New Toronto vacant home tax coming January 1, 2022

On July 15, 2021, Toronto City Council approved a plan for implementing a new tax on the city’s vacant homes beginning in 2022. The proposed tax appears to be very similar to the “empty homes tax” already in force in…

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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Federal Court of Appeal confirms trust deed gave public corporation de facto control over a private corporation wholly owned by the trust

In Bresse Syndics Inc. v. The Queen, 2021 FCA 115 (sub nom. CO2 Solution Technologies Inc.), the Federal Court of Appeal (“FCA”) considered the extent to which a public corporation (“Pubco”) held de facto control over a corporation (the…

Prepared by: Leonard Gilbert

Leonard graduated from the University of Toronto, Faculty of Law (J.D. 2015) and is currently a partner 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 »

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Federal Court finds CRA incorrectly conflates amending an election with rectification

In Brent Carlson Family Trust v. Canada (National Revenue), 2021 FC 506, two family trusts made requests to amend elections for the 2014 taxation year filed under subsection 85(1) of the Income Tax Act (Canada) (the “Act”) in respect…

Prepared by: Leonard Gilbert

Leonard graduated from the University of Toronto, Faculty of Law (J.D. 2015) and is currently a partner 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 »

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Documents requested pursuant to a requirement for information under s. 288(1) of the Excise Tax Act (Canada) need not be proportional to matter at issue

In Canada (National Revenue) v. 2276230 Ontario, 2021 FC 242, the Federal Court granted a compliance order to the CRA citing the Federal Court of Appeal’s decision in Canada (National Revenue) v. Cameco Corporation, 2019 FCA 67, for…

Prepared by: Leonard Gilbert

Leonard graduated from the University of Toronto, Faculty of Law (J.D. 2015) and is currently a partner 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 »

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Senate Passes Significant Tax Bill Aimed at Facilitating Intergenerational Business Transfers

On June 22, 2021, the Senate passed Bill C-208 (following its previous passage in the House of Commons). A Private Members’ Bill, Bill C-208 is aimed at facilitating intergenerational business transfers and follows similar Bills introduced by various political parties…

Prepared by: Alexander Demner, TEP

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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CRA Updates Guidance on Competent Authority Assistance

On June 1, 2021, the CRA published Information Circular IC71-17R6 (“IC71-17R6”), which provides guidance on obtaining assistance under a mutual agreement procedure (“MAP”) article of a Canadian tax convention. New IC71-17R6 replaces and cancels its predecessor IC71-17R5 dated January…

Prepared by: Leonard Gilbert

Leonard graduated from the University of Toronto, Faculty of Law (J.D. 2015) and is currently a partner 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 »

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COVID-19 Tax Update: Tax Court Announces Further Cancellations

On June 1, 2021, the Tax Court of Canada released a further Notice to the Public and the Profession regarding its upcoming hearing schedule.

Previously, the Court issued a Notice cancelling all in-person hearings up to July 16, 2021 as a…

Prepared by: E. Rebecca Potter

Becky Potter is a partner practicing in the firm’s Toronto office. Known for her strategic approach, honed advocacy skills, and breadth of tax knowledge, Becky Potter is a highly sought-after tax litigator. She has successfully represented her clients at every… more »

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