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 [...]
UMMAT TAX LAW PC: MISSION STATEMENT We will strive to meet the needs of our clients and justify their trust in us. We will earn their loyalty and in so doing we will demonstrate how [...]
Non-Resident Ban on Buying Homes The Prohibition Act came into force on January 1, 2023. This prohibits non-Canadians from purchasing residential property in Canada, either directly or indirectly, until January 1, 2025. Ignoring these new [...]
Underused Housing Tax Demystified The Underused Housing Tax (“UHT”) is a federal tax of 1% of a residential property’s value, applied annually to certain owners of underused or vacant residential property in Canada. The tax [...]
