Taxation

Practice

IRS may require snowbirds stuck in the US to file tax returns

Snowbirds caught in the US due to COVID-19 may face tax issues, says Gabriel Castillo
Practice

Message to Canadian owners of US rental properties: The IRS is going to be in your neighbourhood

The IRS will roll out a new enforcement campaign later this year
Thought Leaders

Paying for the pandemic: Why the government’s massive coronavirus spending may not lead to higher taxes

Will pandemic debt require raising taxes and spending cuts in the future?
Thought Leaders

CRA Audit Activity: The Calm Before The Storm?

Trump's tax cuts and deficit spending will increase CRA's vigorous audit activities
Business

Editorial: Canada should zero-rate PPE for GST/HST purposes

The COVID-19 pandemic has taught us PPE is essential and should be zero-rated, says Cyndee Todgham Cherniak of LexSage
Practice

Equity, deadline and when CRA is at fault

A Canadian tax lawyer analysis of Dutka v. The Queen
Business

Loblaw wins appeal of $368 million Tax Court of Canada case

Decision benefits shareholders, pleases Loblaw, angers tax fairness advocates
Practice

Tax disputes and tax filing and payment relief efforts in the age of COVID-19

Joseph A. Gill of McKercher LLP reviews changes to tax deadlines
Transfer Pricing

Transfer pricing & APA considerations during an economic disruption

Mark Kirkey of Gowling WLG on transfer pricing in the new economic reality
Profession

Suing the Canada Revenue Agency for negligence

Upper level costs awarded to CRA in lengthy accounting case over SR&ED credits
Practice

The Tax Court Of Canada tests a new procedure – The Preliminary Ruling Docket

2020 initiative driven by increased objections, case backlog
Thought Leaders

Put your trust in taxes during the coronavirus pandemic recovery

Governments amend taxes for good times and bad, says Andrew Bauer
Practice

Crown bound by settlement agreement to allow losses it claimed to be a fiction

Gergely Hegedus of Dentons Canada on a recent Federal Court of Appeal decision
Practice

1074022 B.C. Ltd. v. Li: The need for legislative reform

A misinterpretation of section 116 of the Income Tax Act in a BC real estate case
Profession

Coronavirus tax relief: Finally some good news for accountants

Sole practitioners, small firms will benefit most from deadline extensions
Profession

CRA further circumscribes trust 21-year planning strategies involving non-resident beneficiaries

The CRA's stated positions will result in a chill on tax practitioners' advice to their clients, says Stephen Sweeney of Miller Thomson
Practice

Scott v The Queen: The importance of evidence

How two brothers came under the scrutiny of the Tax Court of Canada
Thought Leaders

Inheritance tax, wealth tax and more capital gains tax: The future of Canadian taxation?

Canadian tax policy has become a hotbed of new ideas, writes Margaret O'Sullivan
Practice

Donor Beware: The pitfalls of participating in a donation tax shelter

The Tax Court of Canada case Abreo v. The Queen
Thought Leaders

Ottawa should forget about limiting interest expense deductibility

Allan Lanthier on the OECD's proposal to limit excessive debt leveraging
Thought Leaders

Carbon pricing may be overrated, if history is any indication

History proves radical technological change can be achieved by state intervention
Practice

The case of Muir v The Queen

Tax Court of Canada allows appeal over a section 160 assessment by the CRA
Practice

A sad story about Mr. X. from country Y

Canadians are deemed guilty in an unfair tax system, says Tax Lawyer Dale Barrett
Practice

Hamad v. The Queen

Canadian tax lawyer and accountant David Rotfleisch on due diligence In director liability for taxes
Thought Leaders

France-US skirmish over Amazon digital tax

Shows why the century-old international tax system is broken, says Professor Ruth Mason