On June 29, 2021, Bill C-208 received Royal Assent. As previously discussed, that Bill amended the federal Income Tax Act (the “Act”) with the intention of facilitating intergenerational business transfers. The amendments sought to accomplish those means by, in…
Section 160 of the Income Tax Act (Canada) (the Act) is a collection tool that the Canada Revenue Agency (CRA) may use to collect unpaid tax debts of a taxpayer from third parties. This provision applies where a tax debtor…
In Zeifmans LLP v. MNR, 2021 FC 363, the Federal Court considered whether a requirement for information regarding unnamed persons issued to an accounting firm was properly made under section 231.2 of the Income Tax Act (Canada) (the “ITA”).…
The Tax Court’s decision in Leonard v. The Queen, 2021 TCC 33, analyzed the oft-discussed legal concept of “an adventure or concern in the nature of trade”, which the courts use to distinguish between transactions of a business nature…
On March 25, 2021, the Supreme Court of Canada (“SCC”) delivered its much-anticipated judgment on the constitutional validity of the Greenhouse Gas Pollution Pricing Act (“GGPPA”), the statute which enacts the federal government’s carbon pricing standard in relation to…
On July 15, 2021, Toronto City Council approved a plan for implementing a new tax on the city’s vacant homes beginning in 2022. The proposed tax appears to be very similar to the “empty homes tax” already in force in…
In Bresse Syndics Inc. v. The Queen, 2021 FCA 115 (sub nom. CO2 Solution Technologies Inc.), the Federal Court of Appeal (“FCA”) considered the extent to which a public corporation (“Pubco”) held de facto control over a corporation (the…
In Brent Carlson Family Trust v. Canada (National Revenue), 2021 FC 506, two family trusts made requests to amend elections for the 2014 taxation year filed under subsection 85(1) of the Income Tax Act (Canada) (the “Act”) in respect…
In Canada (National Revenue) v. 2276230 Ontario, 2021 FC 242, the Federal Court granted a compliance order to the CRA citing the Federal Court of Appeal’s decision in Canada (National Revenue) v. Cameco Corporation, 2019 FCA 67, for…
On June 22, 2021, the Senate passed Bill C-208 (following its previous passage in the House of Commons). A Private Members’ Bill, Bill C-208 is aimed at facilitating intergenerational business transfers and follows similar Bills introduced by various political parties…
