The Role of an Expert in Tax Cases
What is the Role of an Expert in Tax Cases? The role of an expert in tax cases is to assist the court by providing specialized knowledge, analysis, and opinion evidence on technical or complex [...]
Navigating Canada’s New Capital Gains Transition Rules: A Comparison of June and August Draft Tax Legislation
Navigating Canada’s New Capital Gains Transition Rules: A Comparison of the Department of Finance’s June and August Draft Legislation By Amit Ummat In the Federal Budget released on April 16, 2024, the Government of Canada [...]
Watts Tax Case: Section 160 Applies to Transfer for Home Purchase
[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 [...]
Non-Resident Ban on Buying Homes
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 [...]
What is the Underused Housing Tax?
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 [...]
Taxpayer’s Management Services Not a Personal Endeavour
Taxpayer’s Management Services Not a Personal Endeavour Brown v. Canada 2022 FCA 200 Summary The Appellant Mr. Darrell Brown (“Mr. Brown”) appealed his reassessments to the Tax Court of Canada (“TCC”) and lost. He appealed [...]
Tax Reporting Headache – Reportable & Notifiable Transactions
Tax Reporting Headache - Reportable & Notifiable Transactions Lawyers can usually assist with implementing tax-driven reorganizations cooked up by tax accountants without having to worry about the related tax reporting. A lawyer who prepares a [...]
Tax Court of Canada Settlement Conferences
Tax Court of Canada Settlement Conferences The conventional settlement conference is the preferred apparatus most used by parties trying to settle a tax appeal. A settlement conference is a confidential conference where the parties and [...]
Taxpayer Not Entitled to Deduct Losses on Income Account
Taxpayer Not Entitled to Deduct Losses on Income Account Procon Mining & Tunnelling Ltd. v. HMQ 2022 TCC 71 Decision Here Summary This is a simple case of whether shares owned by a taxpayer were [...]
Avoiding a CRA Audit
Avoiding a CRA Audit By Amit Ummat, Ummat Tax Law PC We have many clients who are self-employed. We also represent professionals and businesses who are required to keep their own books and a variety [...]