Tax Litigation Video Series - Recent Changes To The GAAR

Canada's new Productivity Mega Deduction promises to slash the marginal effective tax rate on business investment to just 6.4%, positioning the country as the most competitive G7 nation for capital deployment. This permanent tax incentive extends immediate expensing to roughly 65% of capital assets, fundamentally reshaping the economics of investing in Canadian operations across manufacturing, energy, technology, and resource sectors.

The Canada Revenue Agency has announced a new priority system for advance income tax ruling requests, targeting investments of at least $1 billion in Canada. This initiative aims to accelerate the tax certainty process for major investors by reducing processing times and providing binding guidance on how specific Income Tax Act provisions apply to proposed transactions.

Canada's new Productivity Mega Deduction permanently provides immediate expensing for a wide range of depreciable property and Canadian development expenses, dramatically expanding the scope beyond the previously announced Productivity Super Deduction. The measure aims to reduce Canada's marginal effective tax rate on new business investment to 6.4%, positioning it as the lowest among major economies and less than half the U.S. rate.

Le paysage fiscal canadien connaît des transformations majeures avec l'élargissement des pouvoirs de vérification de l'ARC, l'utilisation accrue de l'intelligence artificielle dans l'administration fiscale, et la mise en œuvre d'un nouveau régime de prix de transfert. Les entreprises doivent également naviguer les implications fiscales complexes des tarifs douaniers canado-américains et comprendre les récentes décisions judiciaires qui façonnent l'interpr

When the holiday season approaches and the calendar year nears its end, many Canadians look to support the causes they care about while also managing their tax position.

Pleading guilty to a tax fraud charge is rarely the end of a taxpayer’s troubles. In Bernier v The King, a taxpayer who pleaded guilty to Income Tax Act and Excise Tax Act offences in 2022 tried, more than three years later, to reopen his case.

Canadian business owners increasingly ask whether Bitcoin, Ethereum, stablecoins and other crypto-assets should be purchased personally or through a corporation. The question commonly arises where an operating company has accumulated retained earnings and the owner-manager does not need to withdraw all of those funds for personal spending.

If you have held or traded cryptocurrency or NFTs through a Canadian platform in the past several years, the Canada Revenue Agency may already have your account details, and you may not know it yet.

Bitcoin holders around the world woke up on July 31, 2026, to unsettling news: attackers had drained roughly 600 bitcoin, worth close to $40 million, from several hundred Coldcard hardware wallets in a matter of minutes. Coldcard is a bitcoin-only hardware wallet built by Coinkite, a Canadian technology company.

If CRA has proposed a net worth or indirect verification tax assessment against your restaurant based on estimated alcohol or food sales, here is how we push back: by testing the tax auditor’s methodology itself, not just the final number it produced.

For individuals considering international relocation to or from Canada or the United States, careful preparation can help address the tax, immigration and wealth implications of establishing residence in a new country.

Canada's robust economy and stable political environment continue to attract foreign engineers and engineering companies seeking growth opportunities. For firms looking to expand into the Canadian market, understanding the requirements for company structure, regulatory compliance, and management processes is essential to successfully establishing operations eligible to perform engineering services in Ontario.

The Competition Bureau has signaled increased enforcement activity regarding exclusive use clauses in commercial leases following amendments to the Competition Act. This update examines emerging responses from the commercial leasing industry and provides guidance on factors landlords and tenants should consider when negotiating lease restrictions in light of heightened regulatory scrutiny.

What are the critical timing requirements franchisors must follow when delivering disclosure documents to prospective franchisees? Jennifer Shayko explores the specific deadlines mandated by Ontario's Arthur Wishart Act and explains the strategic considerations franchisors should keep in mind to ensure compliance and protect their interests.

Canada's whisky and spirits market presents significant opportunities for international producers, but success requires careful navigation of a dual regulatory framework. Federal laws govern production standards, excise duties, and labelling requirements, while each province maintains its own liquor authority controlling distribution, sales, marketing, and pricing within its borders. Understanding these overlapping jurisdictions and tailoring market entry strategies to provincial variations is essential for

Can a company founder and shareholder who signs a consulting agreement still be classified as an employee? The Ontario Court of Appeal's decision in Pringle v. Zenova Group PLC examines...

Madison Square Garden Sports Corp. has filed a confidential Form 10 registration statement with the SEC to separate its New York Knicks and New York Rangers franchises into two distinct publicly traded companies. The proposed spin-off aims to provide each organization with enhanced strategic and financial flexibility, a more defined business focus, and clearer investment characteristics.

Ontario's Arthur Wishart Act establishes comprehensive franchise disclosure requirements and strict penalties for non-compliance, fundamentally shaping the relationship between franchisors and franchisees. Understanding these regulatory obligations is essential for anyone involved in franchise operations within the province. This video explores the key protective measures and legal framework governing franchise relationships under Ontario law.

Canada's anti-counterfeiting enforcement framework places the burden on rights holders to protect luxury brands through civil proceedings, criminal enforcement, and customs detention. This article examines the practical enforcement mechanisms available after counterfeit activity is identified, including injunctions, evidence preservation, destruction orders, and monetary relief, while analyzing recent Canadian precedents that guide enforcement strategy.

Luxury brands operating in Canada face critical challenges at the border when combating counterfeit goods. The Canada Border Services Agency's Intellectual Property Rights Program offers powerful enforcement mechanisms, but requires formal enrollment and rapid response to detention notices. Understanding the statutory framework, operational mechanics, and response planning is essential before a detention occurs.