Update On Cross-Border Taxation Issues In Canada: Inbound And Outbound

The Canada Revenue Agency has confirmed that tax audits can be settled before completion, but significant cases require multiple layers of internal review and approval. Understanding CRA's internal settlement processes, including the role of the Audit File Resolution Committee, can help businesses develop effective strategies for resolving disputes efficiently and avoiding costly objections.

Canada's Prime Minister Mark Carney has unveiled the "Productivity Mega Deduction," a permanent tax measure providing immediate 100% write-offs for approximately 65% of business assets, positioning Canada's marginal effective tax rate on new business investment at 6.4% - the lowest among major economies. Alongside this initiative, the Canada Revenue Agency will now prioritize advance income tax rulings for investments exceeding $1 billion, aiming to deliver decisions within 90 business days to accelerate ma

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.

As organisations continue to navigate their responsibilities under the Building Safety Act, understanding competence, organisational capability and governance has never been more important. This video explores how expectations around competence have evolved since the introduction of the Building Safety Act and what organisations should be doing to meet their legal obligations, covering both individual and organisational competence requirements.

Employers that rely on the Temporary Foreign Worker Program (TFWP) to retain skilled temporary foreign workers (TFWs) via high-wage or low-wage stream Labour Market Impact Assessments (LMIAs) are facing a growing crisis.

Prime Minister Mark Carney announced on September 15, 2026, that the federal government will open Canada’s four largest airports to private investment through long-term concession arrangements. Speaking at the inaugural investment summit, Prime Minister Carney outlined a vision to unlock new capital and operational expertise while retaining public ownership of the underlying land and assets.

Health Canada's recent enforcement action against unauthorized injectable peptides signals a regulatory shift that wellness companies cannot afford to ignore. While peptides dominate influencer marketing and online wellness spaces, their legal status in Canada depends on factors far more complex than social media trends suggest. Understanding how route of administration, therapeutic claims, and market authorization intersect is now critical for compliance.

Canadian data centre development is entering a critical phase as provincial governments introduce new frameworks for power allocation and pricing. With electricity access becoming increasingly competitive and conditional, developers face evolving regulatory landscapes in British Columbia, Ontario, Alberta, and Québec that could fundamentally reshape project economics and timelines.

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 rapid expansion of data centre infrastructure has made these facilities a focal point for technological innovation and intellectual property investment. From server configurations to advanced cooling systems, the technologies deployed inside data centres represent significant R&D expenditure and competitive advantages. Patent protection offers operators and developers opportunities to safeguard innovations...

Todd Burke of Gowling WLG's International Board sits down with British High Commissioner Rob Tinline to explore the evolving Canada-UK partnership and the commercial opportunities emerging across priority sectors like quantum computing, naval shipbuilding, and nuclear energy. Their discussion examines how these two nations are working together to advance trade, embrace innovation, and reduce barriers to cross-border collaboration in an increasingly competitive global landscape.

A recent Ontario Court of Appeal decision provides important guidance for commercial lenders, borrowers, and guarantors on what happens when a loan is accelerated following default.

The Comprehensive and Progressive Agreement for Trans-Pacific Partnership entered into force between Canada and the United Kingdom on September 1, 2026, fundamentally reshaping bilateral trade relations and investment frameworks. This development arrives as Canada actively diversifies away from U.S. trade dependence while the UK advances its post-Brexit global strategy, creating expanded market access for businesses on both sides of the Atlantic.