Articles 2019

The taxpayer successfully appealed to the FCA in Loblaw Financial Holdings Inc. v. The Queen, 2020 FCA 79. The FCA overturned the TCC’s decision to include over $473 million in the taxpayer’s income as foreign accrual property income.

This is the third installment of the OBA Tax Section's Q&A series with women lawyers in tax. The objective of this series is to give insight into the tax law career possibilities and practice areas that women can have, to give advice to junior tax lawyers or students who may be considering tax, and to shine the spotlight on women leaders in tax.

Ontario’s 2020 economic and fiscal update was delivered on March 25, 2020 and includes new measures that respond to economic concerns as a result of COVID-19.

This article discusses the tax treatment of home office expenses for employees.

This article offers a legislative suggestion for promoting the development of purpose-built rental housing in Toronto.

This article discusses tax issues that can arise in respect of executor compensation and presents an important planning tip.

This is the second installment of the OBA Tax Section's Q&A series with women lawyers in tax. The objective of this series is to give insight into the tax law career possibilities and practice areas that women can have, to give advice to junior tax lawyers or students who may be considering tax, and to shine the spotlight on women leaders in the tax profession. In this quarter, we feature Laura White, a retired partner from Borden Ladner Gervais LLP.

Both the TCC and the FCA agreed with the basic proposition that a duly executed settlement agreement between the CRA and a taxpayer must be adhered to by the parties. The CRA was unable to resile from their settlement.

The process for tax remission can be celebrated for its flexibility in addressing unforeseen circumstances that affect specific taxpayers. Making a request for remission should not be overlooked on the appropriate facts.

On December 5, 2019, the Supreme Court of Canada dismissed the taxpayer’s leave to appeal in Van Steenis v Canada, 2019 FCA 107, an interest deductibility case where the taxpayer borrowed money to purchase mutual fund units, which he did not dispose of, but used returns of capital from those units for personal purchases.