Incentivizing construction of new rental homes is a key policy priority for Canadian governments. As discussed in an earlier post, the federal Department of Finance issued a news release on September 14, 2023 relating to...more
On April 16, 2024 (“Budget Day”), the federal government released its annual budget (“Budget 2024”), which includes certain sales and excise tax measures and also confirms the government’s intention to proceed with several...more
On November 21, 2023, the Government of Canada released its Fall Economic Statement (“2023 FES”) which includes certain sales and excise tax measures, including draft legislative proposals to implement long-awaited new...more
This dispute arose when the Canada Revenue Agency (“CRA”) reassessed President’s Choice Bank (“PCB”) for uncollected GST/HST on bundled supplies made to a major Canadian bank (the “Bank”) and denied the Bank’s rebate claims...more
Le 14 septembre 2023, le gouvernement fédéral a annoncé un allègement bienvenu qui touchera les propriétaires et les promoteurs d’immeubles d’habitation construits expressément pour la location, de logements pour étudiants et...more
On September 14, 2023, the federal government announced a welcome relief that will affect owners and developers of purpose-built rental buildings, student housing or seniors housing....more
On September 14, 2023, the Department of Finance Canada issued a news release (the “News Release”) regarding proposed legislation to be enacted in order to enhance the existing GST New Residential Rental Property (“NRRP”)...more
In July 2023, the Canada Revenue Agency (“CRA”) released GST/HST Notice 325 (the “Notice”) with respect to services provided by certain insurance intermediaries. The Notice essentially makes official the 180-degree turn the...more
Le 4 août 2023, le ministère des Finances (le « ministère ») a publié de multiples propositions législatives et notes explicatives connexes (les « propositions du 4 août »). Ces propositions du 4 août comprennent des...more
On August 4, 2023, the Department of Finance (Finance) released a significant package of draft legislative proposals and related explanatory notes (August 4 Proposals). The August 4 Proposals include updated legislative...more
On June 27, 2023, the Tax Court of Canada (“TCC”) dismissed the appeal of a Schedule II bank (the “Bank”) regarding its entitlement to input tax credits (“ITCs”) for GST/HST payable on expenses incurred in connection with the...more
On June 8, 2023, the Federal Court of Appeal upheld a Tax Court of Canada decision that, by allowing a supplier of Automated Teller Machines (“ATMs”) to place and operate ATMs throughout its casino resort, a casino operator...more
On December 22, 2022, the Court of Appeal of Québec upheld a Superior Court ruling that GST and QST input tax credits and refunds (“ITCs/ITRs”) claimed by a petitioner in connection with damage payments arising from...more
In an informal procedure decision, Axelrod v. The King, rendered on December 12, 2022, the Tax Court of Canada dismissed the appeals of a dentist denying input tax credits (“ITCs”) claimed in connection with certain expenses...more
On July 19, 2022, the Tax Court of Canada (“TCC”) dismissed a major Canadian Bank’s appeal (the “Bank” or the “Appellant”) regarding the characterization of a supply made by the President’s Choice Bank (“PCB”) to the Bank....more
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 April 7, 2022, the Government of Canada unveiled its 2022 federal budget (“Budget 2022”) and announced certain important commodity tax measures. Budget 2022 includes proposed amendments to past proposals, as well as some...more
On December 6, 2021, the Federal Court of Appeal (“FCA”) affirmed the Federal Court’s decision in Denso Manufacturing Canada Inc. v. Canada (National Revenue), which had dismissed the taxpayers’ application for judicial...more
En raison de la situation engendrée par la pandémie mondiale, le gouvernement fédéral a reporté le dépôt de son budget, qui était prévu pour mars 2020, et a plutôt présenté, le 30 novembre 2020, l’Énoncé économique de...more
With the onset of the global pandemic, the federal government postponed its budget for March 2020 and, instead, delivered a Fall Economic Statement (FES): Supporting Canadians and Fighting COVID-19 on November 30, 2020. The...more
Quick Summary. In 1867, the United Kingdom passed a Parliamentary act establishing what is now known as Canada. Today, Canada, the largest country in the Western Hemisphere, is a federation of ten provinces and three...more
On March 19, 2019, the Minister of Finance introduced Canada’s 2019 federal budget (2019 Budget). The government had already signalled that the primary focus of the 2019 Budget would not be business concerns as those had been...more
In a unanimous decision issued November 8, 2018, the Supreme Court of Canada granted the appeal of the decision of the Federal Court of Appeal in Canada v Callidus Capital Corp, 2017 FCA 162. Secured creditors who receive...more
Canada’s tax rules are complex and subject to change. The information contained herein is not, and is not intended, to be a comprehensive overview of Canada’s tax system. Canada’s federal income tax system for businesses...more
On May 25, 2018, the Federal Court of Canada released its decision in Her Majesty the Queen v The Toronto-Dominion Bank. The case revolved around whether the proceeds of the sale of a house by a debtor of Toronto-Dominion...more