Searching Content indexed under Tax by Borden Ladner Gervais LLP ordered by Published Date Descending.
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Supreme Court Of Canada Won't Reconsider The GAAR In Birchcliff Energy Ltd.
On November 14, 2019, the Supreme Court of Canada denied the taxpayer's application for leave to appeal from judgment of the Federal Court of Appeal in Birchcliff Energy Ltd. v The Queen, 2019 FCA 151.
27 Nov 2019
The Billionaire's Audit: Québec Taxpayer Awarded Damages For Negligent RPI Audit
In 2005, the Canadian Revenue Agency (CRA) launched the Related Party Initiative (RPI), more commonly referred to as the High-Net-Worth Project or the Billionaire's Audit.
26 Nov 2019
What To Refuse? Ontario Court Clarifies Scope Of Discovery Of A Representative Plaintiff
In Lipson v. Cassels Brock & Blackwell LLP, Justice Perell revisited the scope of examinations for discovery in class action proceedings.
25 Nov 2019
Taxpayer Challenges Procedural Technicality And Wins: Objecting To A Notice Of Assessment
Revenu Québec refused certain business expenses claimed by the defendant (the Taxpayer) for the 2005 to 2010 taxation years, as well as for 2012.
14 Nov 2019
Canadian FATCA Compliance Update
The Internal Revenue Service has issued revised Foreign Account Tax Compliance Act guidance on the requirement for foreign financial institutions in Model 1 jurisdictions to provide a U.S. tax identification number.
12 Nov 2019
Misrepresentation Of Business Expenses Exposes Taxpayer To Reassessment Beyond Normal Reassessment Period
Following a reassessment raised on November 19, 2018, the defendant (Taxpayer) was denied business expenses claimed for his 2013 ($6,104), 2014 ($4,246) and 2015 ($3,929) taxation years
21 Oct 2019
SLFI Group — Federal Court Of Appeal Confirms That Funds May Unbundle And Outsource Fund Managers' Exempt Financial Services
SLFI Group v. Canada1(SLFI Group) is an important decision from the Federal Court of Appeal (FCA) with respect to the application of GST/HST to fund management activities.
7 Oct 2019
Taxpayer Relief – T1135
Canadian residents2 who own specified foreign property (SFP) that has a cost of over $100,000 during the year must complete form T1135, ...
23 Sep 2019
Tournier v. The Queen 2018 TCC 229
The taxpayer practiced as a lawyer for 27 years before ultimately retiring from the profession in 2013. In preparation for retirement,...
23 Sep 2019
Register Before It's Too Late: New Qst Registration Requirements For Non-Residents Of Québec
As of September 1, 2019, non-Québec resident Canadian investment fund managers, portfolio managers and dealers may be required to register for QST.
30 Aug 2019
Husky Oil – Tax Court Reaffirms Basic Rules Of A Pleading
​Tax litigation can be a very complex process. Many of the rules and procedures that govern tax disputes are designed to match the mechanics of the federal tax system in Canada, including GST/HST
22 Aug 2019
Mandatory Disclosure Requirement Of Nominee Agreements
As part of its initiative to protect the integrity and fairness of its tax system, the provincial 2019-2020 budget put an emphasis on the disclosure requirement of nominee agreements.
13 Aug 2019
Mutual Fund Trusts — Revised Proposals Relating To Allocation To Redeemers
This year's federal budget contained proposed amendments to the Income Tax Act (Canada) (Tax Act) that targeted the "allocation to redeemers" methodology used by certain mutual fund trusts and unit trusts (the Budget Proposals).
9 Aug 2019
Les comptes bancaires hors province sous la loupe de Revenu Québec – une décision importante de la Cour suprême du Canada
La Cour suprême du Canada vient confirmer la décision de la Cour d'appel du Québec en faveur des autorités fiscales québécoises relativement à l'affaire 1068754 Alberta Ltd. c. Agence du revenu du Québec, dont nous avons discuté sur ce site l'an dernier.
19 Jul 2019
Out-Of-Province Bank Accounts Are No Longer Immune From Scrutiny By Quebec Tax Authorities, Says The Supreme Court Of Canada
In the recent decision in 1068754 Alberta Ltd. v. Agence du revenu du Québec, the Supreme Court of Canada confirmed a Quebec Court of Appeal decision permitting Quebec's tax authorities to require the production of bank records of the Calgary branch of a financial institution doing business in Quebec.
19 Jul 2019
Upcoming Changes To The Taxation Of Employee Stock Options
In Budget 2019, the Government of Canada announced its intention to limit the current employee stock option tax regime, moving towards aligning Canada's tax treatment of such options with the United States
10 Jul 2019
Non-Residents Of Canada Not Required To Disclose Books And Records To The CRA
The Minister of National Revenue (the Minister) sought an order from the Federal Court to compel three individuals to provide the Canada Revenue Agency with books, records and information required
31 May 2019
Manitoba Drops RST Rate To 7%
On March 7, 2019, the Progressive Conservative government of Manitoba announced that Manitoba's Retail Sales Tax (RST) rate will be reduced by one percentage point from eight per cent to seven percent
1 May 2019
Advance Tax Credit Financing
From a cash flow perspective, many corporations in need of liquidities cannot afford to wait until the end of the fiscal year to receive payment of refundable tax credits.
25 Apr 2019
Alberta Court Of Appeal Confirms Superpriority For Receiver's Fees And Costs
In the recent decision of Edmonton (City) v Alvarez & Marsal Canada Inc., 2019 ABCA 109, the Alberta Court of Appeal has concluded that fees and costs incurred by a court-appointed receiver should have priority.
11 Apr 2019
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