On June 9, 2022, the Tax Court of Canada (“TCC”) allowed CFI Funding Trust’s (“CFI”) appeal in relation with the input tax credits (“ITC”) it claimed for prepaid rent paid in connection with the securitization of automobile...more
On the heels of some recent positive legislative changes regarding the tax treatment of environmental study and community consultation costs, the Canada Revenue Agency (CRA) has revised its administrative guidelines for the...more
In November of this year at the Canadian Tax Foundation’s 67th Annual Tax Conference (Conference), the Canada Revenue Agency (CRA) announced its current positions on Deferred Share Unit (DSU) conversions; payment events for...more