Shielding Non‐Resident's Assets Via A Canadian LP

If the CRA has served you or your accounting firm with a CRA requirement for information, and you are wondering whether you can refuse it, delay it, or fight it later, the Federal Court of Appeal has now answered that question.

On July 2, 2026, the Canada Revenue Agency (CRA) published its updated Guidance on the Common Reporting Standard (Updated CRS Guidance).

The Federal Court has approved an $8.7 million class action settlement in Sweet v. His Majesty the King (2026 FC 590), resolving claims from the 2020 credential-stuffing cyberattacks on Government of Canada online accounts accessed via GCKey, including CRA My Account.

When a specified motor vehicle is acquired through a private sale (for instance, from an individual who is not registered for GST/HST purposes), the transaction is generally not subject to GST/HST.

If you have signed, or are about to sign, an agreement to buy a newly built home in Ontario, the HST you recover could be anything from nothing to $130,000. The difference usually comes down to a signing date, a price threshold, or whose name is on the purchase agreement, and not to whether you are buying your first home.

The GST/HST New Housing Rebate lets a purchaser recover part of the GST/HST paid on a newly built or substantially renovated home used as a primary residence.

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 policy to prioritize advance income tax ruling requests for investments of $1 billion or more in Canada. This initiative aims to provide greater tax certainty and reduce risks for major investors, potentially accelerating large-scale project development and strengthening Canada's economic competitiveness. However, questions remain about implementation timelines and potential impacts on smaller ruling requests.

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.

The federal government has finalized revised reporting rules for bare trusts, significantly narrowing the original requirements. While bare trusts are generally exempt from filing for 2023-2025, certain arrangements involving separated legal and beneficial ownership will face new filing obligations starting with the 2026 taxation year, with specific exemptions for family trusts, joint ownership arrangements, and principal residences.