Navigating Canada’s New Capital Gains Transition Rules: A Comparison of the Department of Finance’s June and August Draft Legislation By Amit Ummat and Alisha Butani In the Federal Budget released on April 16, 2024, the [...]
[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 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 [...]
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 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 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 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 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 [...]
Choosing The Right Tax Litigation Lawyer In the course of my practice, I am routinely asked the question “what makes you any different from the rest?”. It is an excellent question. And it is certainly [...]
