In Canada v Dow Chemical Canada ULC, the Federal Court of Appeal (the “FCA”) confirmed that the jurisdiction of the Tax Court of Canada does not extend to varying or quashing an “opinion”.? Rather, the FCA held that the…
British Columbia is the last province in Canada to introduce marketplace facilitator rules that will require online marketplace facilitators rather than sellers to collect BC PST on sales made through the marketplace.? The proposed legislation is to come into force…
Authors: Gloria Wang, Sarah Faber, and Alexander Demner
Budget 2022: A Plan to Grow Our Economy and Make Life More Affordable (“Budget 2022”) was tabled by the Federal Government on April 7, 2022 (“Budget Day”). The government…
Authors: Jennifer Flood and Greg DelBigio, Q.C.
The 2022 Budget shows once again Canada’s ongoing commitment to the investigation and prosecution of financial crime including money laundering and tax evasion, including by injecting substantial funds into expanding the…
Under the Excise Tax Act (the “Act”), the Minister of National Revenue (“Minister”) and her delegates are granted discretion to make administrative decisions affecting taxpayers on a case-by-case basis, including powers to extend deadlines or waive compliance with certain requirements…
The Supreme Court of Canada (“SCC”) has granted the application for leave to appeal in Agence du revenue du Québec c. Des Groseillers, 2021 QCCA 906.
Des Groseillers concerns the tax treatment of donated employee stock options under…
In Nicole L. Tiessen Interior Design LTD. v Canada (2021 TCC 29), the Tax Court of Canada (“TCC”) found that 30 corporations were deemed to be associated with each other under the anti-avoidance rule in s. 256(2.1) of the federal…
The jurisdictional boundaries between the Tax Court of Canada and Federal Court over taxation matters has often been a trap for taxpayers. In Iris Technologies Inc. v. Canada (National Revenue), 2022 FCA 39 (“Iris Technologies”), the Federal Court of Appeal…
The Supreme Court of Canada (the “SCC”) has granted the application for leave to appeal in Canada v. Deans Knight Income Corporation, 2021 FCA 160 (“Deans Knight”).
Deans Knight deals with the application of the general anti-avoidance rule (“GAAR”)…
The Tax Court of Canada (“TCC”) recently issued a Practice Direction and Order (the “Order”) allowing parties to proceedings covered by the Tax Court of Canada Rules (General Procedure) to consent to be served by e-mail. The Order can be…
