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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.

Throughout 2023, the Government of Canada continued its agenda of major tax reform with new legislative proposals and technical amendments to Canadian tax law affecting the general anti-avoidance rule (GAAR), clean economy tax credits, mandatory disclosure rules, and many more.

On February 18, 2021, the Supreme Court of Canada (SCC) declined to hear the appeal of the Canada Revenue Agency (CRA) from its loss before the Federal Court of Appeal (FCA) in Canada v. Cameco Corporation (2020 FCA 112) (Cameco).

The transfer pricing case of McKesson v. The Queen has raised procedural issues that are without precedent in Canadian tax cases.

The non-arm's length transactions which can be subject to Canadian transfer pricing legislation include tangible products, intangibles, intra-group services and cost-contribution agreements.

A significant chapter in Canadian tax law is being rewritten. On Nov.⁠ 4,⁠ 2025, the federal government tabled Budget 2025, which introduced a comprehensive modernization of Canada's transfer pricing rules under section 247 of the Income Tax Act.

Courts in the second quarter of 2019 will see significant tax-related decisions and developments.

The Canadian income tax system is based on the principles of self-reporting and self-assessment. At first instance, the government does not have sufficient information to determine each person’s income or tax. Accordingly, taxpayers are trusted to report their own income for each year. In order to ensure accuracy of returns, the Canada Customs and Revenue Agency (CCRA) is given broad powers to audit taxpayers’ books and records and obtain other information.

As was expected, the 2019 Federal Budget is one for an election year. Meaning, while the Government provided a few handouts and various credits, there is little to offend anyone – at least from a tax perspective.

The Canada Revenue Agency (CRA) is afforded considerable latitude in administering and enforcing the Income Tax Act (Act). This latitude is reflected in its power to determine the scope of tax audits...

On November 4, 2025, Canada's Minister of Finance tabled the federal budget, Building Canada Strong ("Budget 2025"). From a tax perspective...

In this recent decision, the Tax Court of Canada was tasked with interpreting paragraph 161(7)(b) of the Income Tax Act (the Act), and the timing of loss carrybacks for the purpose of calculating interest on an outstanding tax balance.

In Budget 2013, the Government announced its intention to consult on possible measures to combat treaty shopping.

Action 1 of the BEPS Project is focused on tax challenges associated with digitalisation.

This article provides a brief overview of recent developments in Canadian law relating to American Companies Investing in Canada.

Canada's federal government has proposed the Productivity Mega Deduction, offering permanent 100% first-year expensing for depreciable property and Canadian development expenses in the mining sector. How will this transformative tax measure reshape investment strategies and project economics for mining companies operating in Canada?

The largest initiative the transfer pricing world has seen, since the introduction of the OECD's current Transfer Pricing Guidelines, is in its final stages and will result in material changes in the way the global operations of corporate organizations are structured and international transactions are reported...