ArticleTax And Real Estate – Tax Authorities Scrutinizing TransactionsThe questionnaire is broad, contains over 35 questions and requests significant documentation.CanadaTaxFasken
ArticleTax Changes Coming For Sales Of Linked NotesA linked note is a debt obligation in which the return is linked to the performance of one or more reference assets or indexes.CanadaTaxGrant Thornton
ArticleTax Court Declines To Apply GAAR To Non-CCPC PlanThe Tax Court of Canada ("TCC") recently released the much-anticipated decision in DAC Investment Holdings Inc. v. The King, 2024 TCC 63 ("DAC").CanadaTaxAird & Berlis LLP
ArticleTax Court Finds That Broker Fees On A Private Company Sale Were GST/HST-TaxableThe Tax Court of Canada recently released its decision in Barr v. The Queen, 2018 TCC 86, which considered whether share-sale commissions were exempt from HST. CanadaTaxDavies Ward Phillips & Vineberg LLP
ArticleTax Foresight Correctly Predicts The Case Outcome Of Ahmar V. CanadaAhmar v. Canada, 2020 FCA 65 is an appeal from the Tax Court's decision to hold the taxpayer, who was the sole director and shareholder of a corporation, personally liable for the...CanadaTaxBlue J Legal
ArticleTax Memo: August 14, 2012 - Legislative Proposals: Important International Tax ChangesOn August 14, 2012, the Department of Finance released for consultation draft legislative proposals implementing measures included in the March 29, 2012 federal budget. CanadaTaxPwC Management Services LP
ArticleTax Memo: FCA Decides Attribution Rule Did Not Apply On Sale To Trust By Capital Beneficiary (Sommerer)The Federal Court of Appeal (FCA) released its decision in The Queen v. Sommerer on July 13, 2012, concluding that subsection 75(2) of the Income Tax Act (Canada) does not apply on a fair market sale of property to a trust by a person who is a capital beneficiary of the trust. CanadaTaxPwC Management Services LP
ArticleTax Planning For BusinessVern Krishna of TaxChambers LLP discusses tax planning for business at year-end in a featured article for Canadian Current Tax. CanadaTaxKPK Law LLP
ArticleTaxChambers LLP Newsletter: The Common Reporting Standard (CRS)The Common Reporting Standard (CRS) is a new international standard for the automatic exchange of financial account information between tax authorities of over 100 countries. CanadaTaxKPK Law LLP
ArticleThe CRA Complied With The September 30 FATCA Deadline After The IRS Advised That Notice 2015-66 Did Not Apply To CanadaIn an affidavit that was filed with the Federal Court of Appeal on September 25, 2015 in support of the government's response to block a motion for injunctive relief that had been brought by the plaintiffs.CanadaTaxStikeman Elliott LLP
ArticleThe Three Steps Of GAARPlease see Vern Krishna's latest article for the Taxnet Pro: Tax Disputes & Resolution Centre titled, "The Three Steps of GAAR" where he discusses the general anti-avoidance rule as a statutory commercial...CanadaTaxKPK Law LLP
ArticleThe Underused Housing Tax Act- Filing Requirements That May Be SurprisingThe Underused Housing Tax Act ("UHTA") levies an annual tax on individuals who are neither permanent residents of Canada nor Canadian citizens at a rate of 1% on the value...CanadaTaxRobins Appleby LLP
ArticleUnderstanding The Small Business Tax Changes And Financial Transaction TaxKim Moody speaks with Danielle Smith of QR77 on the recent roll back of small business tax changes that will potentially hurt small business creationCanadaTaxMoodys Private Client Law
ArticleUnderused Housing Tax ActOn January 1, 2022, a tax on underused housing in Canada came into effect. This tax on vacant or underused housing in Canada is the result of the Underused Housing Tax Act...CanadaTaxSpiegel Sohmer
ArticleUnderused Housing Tax Filing Deadline Extended To October 31, 2023The Underused Housing Tax Act (the "Act"), which came into effect on January 1, 2022, implements an annual 1% tax on the value of vacant or underused residential property in Canada...CanadaTaxAird & Berlis LLP
ArticleUnintended ConsequencesTaxes are inevitable. In business transactions, strategic decisions are made to reduce or eliminate the amount of taxes paid.CanadaTaxMiller Thomson
ArticleUpdate On New Canadian Trust Taxation Legislation – Subsection 104(13.4)Almost a year ago, I wrote about a piece of draft legislation – subsection 104(13.4) – that was introduced as part of the proposals to eliminate graduated rate taxation for Canadian resident testamentary trusts. CanadaTaxMoodys Private Client Law
ArticleUpdate To Home Office Expenses Incurred During COVID-19: Can An Employee Deduct Them?The Canada Revenue Agency ("CRA") released an update on the process for claiming home office expenses for the 2021 taxation year.CanadaTaxMcCarthy Tétrault
ArticleUS Estate Tax Exposure For CanadiansCanadian residents who are neither citizens, nor residents, of the United States can be subject to US estate tax?CanadaTaxGrant Thornton