Rectification in the Canadian Tax Context Rectification is an equitable remedy that permits a court to amend a written instrument where it fails to accurately record the agreement that the parties in fact reached. In [...]
The Intersection Between Real Estate Law and Tax Litigation in Canada: Income Tax and GST Considerations Introduction Few areas of Canadian tax litigation generate as much complexity as disputes involving real estate. Real estate transactions [...]
The Intersection of Tax Litigation and Family Law in Ontario: When Family Lawyers Should Involve Tax Litigation Counsel Family law disputes frequently involve complex financial issues, yet the tax consequences of those disputes are often [...]
When Should a CPA Call a Tax Litigator? Most tax disputes are resolved long before a courtroom is ever involved. In many cases, a skilled CPA can manage compliance issues, respond to routine audit queries, [...]
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 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 [...]
[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 [...]
