Articles 2024

Potential ACB increase as a result of a spin-off transaction is viewed by the CRA as subject to GAAR.

Eight commodity tax considerations for commercial landlords in Ontario.

In Tran v. The Queen, the Appellant successfully disputed a director's liability assessment by challenging the underlying assessment. The Appellant proved that the T4s relied upon by the Minister were overstated. The Crown did not challenge this evidence. As the Crown failed to adduce evidence to reduce the underlying assessment, the Tax Court concluded that the underlying assessment was incorrect and found in favour of the Appellant.

The Federal Court ordered that the Minister is authorized to impose on Coinsquare a requirement relating to unnamed persons.  The result is that Coinsquare must produce the requested documents and information about its customers to the CRA.

A review of the recent Federal Court of Appeal decision Canada (Attorney General) v. Honey Fashions Ltd..

Zahra Nurmohamed is an award-winning tax practitioner and former partner in the Toronto office of KPMG Law LLP with over 20 years of experience in Canadian corporate tax matters. She currently serves as Tax Counsel and Senior Director of Professional Development at KPMG Law LLP where she leads the strategic direction and implementation of KPMG Law’s student and associate programs.

Lisa Watzinger is a tax lawyer whose practice focuses on resolving disputes with federal and Ontario revenue authorities. She has appeared before the Tax Court of Canada, the Federal Court of Appeal and the Ontario Superior Court of Justice.

The importance of legal form of real estate transactions and Its GST/HST implications.

There is an uncertain relationship among the concepts of the General Anti-Avoidance Rule ("GAAR"), the normal assessment period, and the role of a taxpayer's state of mind or intention at the time of self-assessment. The uncertain relationship arises when the Minister of National Revenue issues a GAAR (re)assessment after the normal assessment period on a taxpayer with a good faith tax filing position.

This article lays out the basics of the tax implications, and complications, that social media influencers face.