Partnership freeze – A better alternative under the new capital gains rules?
With the advent of the proposed new capital gains rules, renewed consideration is warranted with respect to alternate forms of tax efficient estate planning – such as a partnership freeze. A partnership freeze is a planning technique that has not […]
Department of Finance releases draft legislation limiting expense deductions for short-term rentals
On December 20, 2023, the Department of Finance released for consultation draft legislation to amend the Income Tax Act (the “Act”). The draft legislation is intended to implement the measure previously announced in the 2023 Fall Economic Statement to deny […]
Consultations on measures announced in Budget 2023 begin
On Friday, August 4, 2023, the Department of Finance released for public consultation extensive legislative proposals accompanied by explanatory notes (the “August Proposals”). The August Proposals relate to various measures previously announced in Budget 2023. See here for our 2023 […]
New reportable transaction rules receive Royal Assent
Bill C-47 received Royal Assent on June 22, 2023, bringing into effect the new expanded reportable transaction rules. A failure to report as required by the new rules could result in substantial penalties for both taxpayers and their advisors. Taxpayers […]
Transfer Pricing 2023 – Canada: Law & Practice and Trends & Developments
Chambers Global Practice Guides: Transfer Pricing
David Chodikoff, Andrew Etcovitch, Carolyn Inglis, Daniel Kiselbach, Shashi Malik, Victoria Rodrigues and Marie-Hélène Tremblay are contributors to the 2023 edition of Chambers Global Practice Guides: Transfer Pricing. Both law & practice and trends & developments are highlighted in this […]
“Checking the Box” not enough to avoid director’s liability for outside director
A decision of the Tax Court of Canada has provided further insight into the duties of an “outside” director who wishes to rely on the due diligence defence to avoid a director’s liability assessment under the Income Tax Act (the […]
Release of draft Canadian tax legislation
On August 9, 2022, legislative proposals relating to the Income Tax Act (the “Act”) and other tax legislation were released by the Department of Finance for public feedback (the “August Proposals”). The August Proposals seek to implement certain measures previously […]
Post-COVID emigration: Don’t forget the tax!
As COVID-19 travel restrictions are lifted, individuals who are usually resident in another country but sheltered in place in Canada during the pandemic may decide to return to their countries of residence. Those individuals who are planning to leave Canada […]
Budget 2022: Substantive CCPCs and share transactions involving a non resident or public company
The 2022 Federal Budget was tabled in the House of Commons on April 7, 2022 (“Budget Day“) by the Honourable Chrystia Freeland, Canada’s Deputy Prime Minister and Minister of Finance. A summary of the personal income tax measures, business income […]
Alberta court confirms competent Testator’s right to privacy
In the recent Alberta decision of Duhn Estate, 2021 ABQB 35, the Court of Queen’s Bench has confirmed that, absent a sufficient evidentiary basis, the Court will not displace a testator’s right to keep her pre-death financial life private and […]
