Canadian Federal Budget Proposes Amendments to CRA’s Information Gathering Powers BUDGET FOUND HERE By: Amit Ummat and Alisha Butani Chrystia Freeland, the Canadian Deputy Prime Minister and the Minister of Finance, tabled the 2024 Canadian [...]
Time Extensions for Elections Under Section 217 of ITA(Canada) Are Prohibited By: Amit Ummat and Alisha Butani Section 217 of the Income Tax Act R.S.C., 1985, c. 1 (5th Supp.) (the “Act”) Generally Canadian taxpayers [...]
Overview of Tax Court of Canada’s Ruling in 1351231 Ontario Inc v. The King Air BnB Sale subject to GST/HST DECISION LINKED HERE By: Amit Ummat and Alisha Butani Facts In February 2008, the Appellant, [...]
Overview of Tax Court of Canada’s Ruling in DEML Investments Limited v. The King 2024 TCC 27 DECISION HERE In DEML Investments Limited v. The King 2024 TCC 27 (the “Case”), Justice Bruce Russell was [...]
Ummat Tax Law PC is celebrating 5 years of private practice. We are thankful to our friends, colleagues, and clients for believing in us. We strive to offer excellent representation in all tax litigation matters. [...]
[This first appeared in the Canadian Tax Foundation's 2023 Ontario Tax Conference Materials] Watts v. HMK 2023 TCC 11: Section 160 Applies to Transfer for Home Purchase DECISION HERE Summary Miriam Watts (Appellant) received an [...]
Government of Canada Clarifies Low-Interest Loans Following CAE The Government of Canada provided much-needed clarity on the issue of loans from public bodies in its Fall Statement. Context The Tax Court in CAE v. HMK [...]
Greer v. HMK: Shareholder Benefit from Transfer of Real Property Upheld DECISION HERE Summary The two main issues to be resolved by the Tax Court of Canada (Tax Court) were a) was the Appellant Michale [...]
2018: GAAR in Review at the Federal Court of Appeal (FCA) By Amit Ummat In 2018, the Federal Court of Appeal (“FCA”) decided eight general anti-avoidance rule (“GAAR”) decisions. I plan to survey briefly those [...]
CRA CAN COMPEL TAXPAYERS TO SUBMIT TO ORAL INTERVIEWS Pursuant to the newly enacted subparagraph 231.1(1)(d)(i) of the Income Tax Act, the CRA can now compel a taxpayer to submit to an oral interview. This [...]
