Articles

Following the Canadian Medical Protective Association decision in which the CMPA was exempt from GST, several class action lawsuits were commenced by taxpayers seeking to recover erroneously collected GST from the collector.

Various provisions of the Income Tax Act operate to deem transfer of property, specifically non-arm’s length transfers, to take place at the fair market value of the property.

An amalgamation is defined for the purposes of subsection 87(1) as a merger of taxable Canadian corporations where all of the property, liabilities and shareholders of the predecessor corporations immediately...

On July 1, 2010, the provinces of British Columbia and Ontario became subject to the harmonized sales tax under the Excise Tax Act.

A recent case has given hope to taxpayers who want to seek relief from accrued interest and/or penalties that have roots in a taxation year many years past.

The recent decision in Sommerer v. The Queen, in particular, the interpretation of subsection 75(2) and whether it applied in the context of a fair market value sale of shares by the Appellant, one of the beneficiaries of an Austrian private foundation, to the foundation.

On the final morning of the 2011 Canadian Tax Foundation (“CTF”) national conference, Chief Justice Rip of the Tax Court of Canada (“TCC”) provided an update on recent TCC activities, ...

The implementation of changes to the Mandatory Disclosure Rules as proposed in the 2021 federal budget continues to be a multi-year process. The proposed changes include broadening the scope of the existing reportable transaction rules, enacting notifiable transaction rules and enacting uncertain tax treatment rules. Recently, the government renewed its commitment to implementing the proposed rules, but their coming into force has mixed timing.