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On August 27, 2010, the Canadian government once again released draft legislation to amend the "Income Tax Act" (the "Act") relating to investments in so-called "non-resident trusts" (NRTs).

The Fifth Protocol (the Protocol) to the Canada–U.S. Income Tax Convention (the Treaty) was signed in 2007 and generally took effect in 2009.

Audit, Bar Owners, CRA, David Piccolo, Federal Court, Joe Wahba, Law Society of Ontario, Restaurant Owners, Tax Lawyers, The Beer Store

In Transalta v. The Queen (2012 DTC 1106) ("Transalta"), the Tax Court of Canada concluded that for the stock option rules ...

The Supreme Court of Canada's 2016 and 2022 decisions in the Fairmont Hotels and Collins Family Trust cases respectively have substantially reduced the availability to residents of...

Canada and the U.S. executed a model 1 intergovernmental agreement which relieved Canadian financial institutions from many onerous obligations under FATCA.

On February 18, 2021, the Supreme Court of Canada announced that it will not hear the transfer pricing tax appeal involving the Government of Canada and Cameco Corporation.

Tax Court has implemented a new common books of authorities program for its Toronto courtrooms that will eliminate the need for taxpayers to print copies of certain frequently-cited authorities.

Erhard Unger was convicted in Penticton, BC of failing to file income tax returns and was fined $1,000.

Although it is not often well-understood in business and tax circles, the Indian Act (the "Act"), coupled with federal and provincial tax laws...

As reported in our prior bulletin, "Four Trends in Indigenous Equity Participation in Canada", we have been monitoring reports of Indigenous equity participation in energy and related infrastructure projects.

On October 19, 2017, the Department of Finance Canada issued a news release advising that it will not move ahead with proposed measures intended to target the conversion of income into capital gains.

The reasons and judgment of the Federal Court of Appeal in Wild v. Canada (Attorney General) (2018 FCA 114) are appealed to the Bowman Supreme Moot Court for Tax Appeals.

Bill 105, or the Supporting Small Businesses Act, recently passed a second reading after debate in the Ontario Legislature.

Certain derivatives held on income account have been treated as inventory for tax purposes, thereby allowing the deduction of unrealized losses on such derivatives.