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The Canadian Revenue Agency (CRA) has recently announced that bare trusts are not required to file T3 returns and Schedule 15 for the 2024 tax year, extending from a similar [...]

Introduction: Stack v The King, 2024 TCC 137 In Stack v The King, 2024 TCC 137, the Tax Court of Canada blocked the Canada Revenue Agency's attempt to obtain various [...]

The Probate Process Probate is the legal process through which a deceased person's will is validated by the courts, and the administration of his or her estate is carried out [...]

In September 2024, the Tax Court of Canada delivered its judgment on Fijal v. The King, 2024 TCC 116. The three main issues in the case are: Can the Canada [...]

Introduction: An Overview of Case Laws Helps to Understand Circumstances that May Warrant Relief under the CRA's Taxpayer Relief Provisions for Canadian Taxpayers Under subsection 220 (3.1) of the Income [...]

When CRA Reassesses a Taxpayer after the Agency Accidentally Cancelled his GST Number When a taxpayer ceases to be a GST/HST registrant, he can face a significant tax liability under [...]

Introduction: An ATIP Request Helps Taxpayers to Obtain Government Records Concerning Their Tax Matters. An Access to Information and Privacy (ATIP) request is an online request that allows taxpayers in [...]

Introduction - Director's Liabilities Under the Income Tax Act and the Excise Tax Act (GST/HST) A director of a corporation may be held personally liable when the corporation fails to [...]

EU Court Ruled that Privilege in Tax Matters Extends Only to Lawyers Mossack Fonseca, the law firm involved in the Panama Papers scandal, was closed, but the scandal's impact on [...]

The 2024 taxation year is almost done, and it's time to take advantage of year-end tax-planning strategies that allow you to maximize the tax benefits of your Tax-Free Savings Account [...]

Introduction: When the Subject of Scams Becomes the Victim of Scams Many Canadian taxpayers have encountered scams impersonating the Canada Revenue Agency (CRA), where scammers and fraudsters exploit the agency's [...]

The CRA Does Not Need To Wait To Initiate Collections For GST/HST Subsection 315(2) of the Excise Tax Act grants the CRA extensive authority to immediately collect tax debts from [...]

In August 2024, the Federal Court ('FC') delivered its judgment on Onex Corporation v. Canada, 2024 FC 1247, setting aside the decision of the Canada Revenue Agency ('CRA'), which refused [...]

Introduction: The Nature of Business Income for Tax Purposes A Canadian tax resident is taxable on income from all sources, including from business and property. A taxpayer's income from a [...]

Introduction: CRA Has the Ability to Exchange Tax-related Information with Foreign Taxing Authorities, Subject to Bi-lateral Tax Treaties And Tax Information Exchange Agreements The trend of digitizing tax-related information provides [...]

INTRODUCTION Understanding Your Tax Affairs and Vigilance to CRA Communications is Necessary To Avoid Tax Liabilities Failure to understand your tax affairs or check your CRA online account regularly could [...]

Introduction - Commitment Fee and Break Fee in M&A transactions In March 2024, the Supreme Court of Canada (SCC) denied the application for leave to appeal by Glencore Canada Corporation [...]

Introduction: The Collection-Assistance Provision in Tax Treaties Between Canada And Other Countries As the world becomes increasingly interconnected and tax laws become more onerous, tax authorities around the world, including [...]

The Canadian Federal Government has enacted a controversial Digital Services Tax that will bring in billions of dollars while threatening Canada's trading relationships by taxing the revenue international firms earn [...]

Introduction To Trusts: What Are They? In Canada, a trust is a legal arrangement where one party, known as the trustee, holds and manages assets for the benefit of another [...]

What is an Employer Ownership Trust? An Employee Ownership Trust (EOT) is a Canadian-resident trust designed to hold shares in qualifying businesses on behalf of employees, supporting succession planning and [...]

Introduction - Director's corporation claiming small business deduction In August 2024, the Supreme Court of Canada (SCC) denied the application for leave to appeal to the SCC by the appellant [...]

Introduction: The CRA's Taxpayer Relief Program A Canadian taxpayer may face penalties and interest owing to the Canada Revenue Agency ('CRA') for many reasons, including late filing a return and [...]

Introduction: Derivative Tax Liability under Section 160 of Canada's Income Tax Act Section 160 of Canada's Income Tax Act is a tax collection tool. It prevents tax debtors from trying [...]

More than six years after warning of excessive waiting times and frequently unreliable answers from Canada Revenue Agency (CRA) call centres, Auditor-General Karen Hogan is planning a fresh review after [...]

Introduction - A taxpayer sought an exemption from paying income tax due to abortion law In August 2024, the Supreme Court of Canada (SCC) denied the application for leave to [...]

Canada Revenue Agency's Real Estate Tax Audits Yield $2.7B in additional tax, penalties CRA assessed $2.7 billion in additional tax and penalties from 2015 - 2023, including $1.4 billion in [...]

Remote Work is Still Widespread Across Canada As many employees and employees realize the potential benefits and flexibility that working from home affords, a significant portion of Canadians are still [...]

Introduction: Israel's Pilot Program for a Modern Crypto-Centric Voluntary Disclosures Program for Taxes Gets a Rocky Start Generally speaking, voluntary disclosure programs are administrative programs offered by tax administrators to [...]

Introduction: Challenging CRA Decisions The Canada Revenue Agency (CRA), responsible for administering tax and related programs for Canada, is expected to provide accurate, fair, timely, and professional service, pursuant to [...]

Payments made to non-residents for services performed in Canada can carry significant tax consequences for both the payer and the service provider. Specifically, both parties should be mindful of Regulation [...]

Introduction: Key Criteria Of A Successful Voluntary Disclosure Application Include Completeness, Voluntariness, 1-Year Or 1-Reporting-Period Overdue, Potential Penalties, and Payments. A Voluntary Disclosure Program (VDP) in Canada is a policy [...]

INTRODUCTION: LOSS CARRYOVER CLAIMS EXCEEDING $200,000, ARE MORE LIKELY TO GET AUDITED A routine loss carryover claim could trigger a tax audit. This is especially so, where the taxpayer is [...]

Introduction - How CRA Assessments are Appealed to the Tax Court of Canada The Tax Court is a federal court that has the jurisdiction to deal with matters involving all [...]

Introduction: EOTs Are A New Method For Business Owners To Pass Ownership To Employees Employee ownership trusts (EOTs) are an important tax planning tool for Canadian business owners who plan [...]

Introduction: The GST/HST Change-In-Use Rule under Subsection 206(2) of Canada's Excise Tax Act Canada's Excise Tax Act imposes GST/HST on every 'taxable supply made in Canada.' A 'taxable supply' essentially [...]

Introduction To Non-Resident Withholding Tax When non-residents receive income from Canadian sources, such as dividends, interest, royalties, or rental income, the Canadian government imposes a withholding tax on this income. [...]

Introduction: What Are Employee Stock Options Employee stock options are a benefit offered by companies to their employees, giving them the right to purchase company stock at a set price [...]

Introduction: Landlord's Tax Obligations Canada has, over the years, gradually become a difficult business for landlords. In particular, Canada has grown much less welcoming towards short-term rental units. In fact, [...]

Introduction - The Recent Tax Court Decisions on Taxability of Poker Winnings: Duhamel, Fournier, Berube & D'Auteuil Poker, a game of skill and strategy, has gained immense popularity worldwide. In [...]

Introduction-Form W-8BEN-E: a common request by American suppliers from Canadian businesses The US has always been Canada's largest trade partner. Indeed, as of 2022, trade volume with the US alone [...]

Introduction: A Health Spending Account is a self-insured health plan A Health Spending Account (HSA), also known as a Health Care Expense Account, is an account to be used by [...]

Introduction - The Department of Finance Announces Revised Draft Legislation for Anticipated Capital Gains Changes On August 12, 2024, the Department of Finance released revised draft legislation for the implementation [...]

As the Paris Olympic ended in August 2024, tax experts from the UK warn that British athletes' gold medals could quickly lose their luster if participants unknowingly become liable for [...]

Introduction: The CRA Has an Array of Powers to Enforce Collection of Tax Debt Many taxpayers find themselves in situations where they are overburdened by tax debts on top of [...]

2024 has been a difficult year for many property owners in Canada, in light of the high mortgage rates, increased capital gains tax, and the slow real estate market. Many [...]

Introduction: Resolving Cryptocurrency-Related Tax Delinquency under the CRA's Voluntary Disclosures Program (VDP) Our knowledgeable Canadian crypto-tax lawyers have assisted numerous Canadian cryptocurrency traders, cryptocurrency investors, and cryptocurrency miners with correcting [...]

Introduction: A Canadian Property Owner's Increasing Tax and Reporting Obligations Canada has a housing crisis. The government of Canada openly admits that the 'national housing crisis presents one of Canada's [...]

If you sell goods or provide services in Canada, you likely need to register for and charge customers the Goods and Services Tax ( GST) or the Harmonized Sales Tax [...]

Appropriate Tax Treatment for a Specific Income Tax Provision: Who Determines? The provisions of the Income Tax Act can pose significant challenges for those unfamiliar with legislative language. Moreover, the [...]