The Income Tax Act (Canada) (the “ITA”)) contains strict requirements for notices of objection filed by a “large corporation”. A recent Tax Court of Canada (“TCC”) decision – 641624 Alberta Ltd v R, 2026 TCC 67 – illustrates that…
Following our previous discussion of Canadian tax residency, this post explores the next question: what happens when a taxpayer becomes a non-resident of Canada under the Income Tax Act (Canada) (the “ITA”)?
Whether a taxpayer’s “exit” is tax motivated or…
Under the Income Tax Act (Canada) (the “ITA”), a resident of Canada is taxable on worldwide income, whereas a non-resident is taxable only on certain income that is connected to Canada. Non-residents are also subject to withholding tax on certain…
Authored by: Adrian Zee, Rosemary Anderson, and Zheting Su
The recent 2026 BC Budget announced amendments (the “Amendments”) to the Provincial Sales Tax Act (“PSTA”) to eliminate certain exemptions and expand the application of PST to…
At the 2025 CTF Annual Tax Conference, during their annual 2025 roundtable (the “2025 Roundtable”) the Canada Revenue Agency (the “CRA”) answered questions regarding its current administrative views and practices. This blog provides an overview of certain key takeaways from…
The Canada Revenue Agency (the “CRA”) administers the Voluntary Disclosures Program (“VDP”) to grant penalty and/or interest relief to taxpayers who voluntarily disclose errors or omissions in their past tax filings and pay the taxes owing, provided they meet the…
Overview
The Tax Court of Canada Rules (General Procedure) provide that a party may be entitled to substantial indemnity costs if the party makes a settlement offer and ends up obtaining an outcome at trial as favourable as or…
Overview
Tax disputes generally hinge on whether the imposition of taxes and penalties is correct. However, there are situations where a taxpayer can be granted relief from the imposition of penalties and/or interest even if they were correctly levied. Subsection…
The Canada Revenue Agency (the “CRA”) is granted significant powers to gather information from persons under the Income Tax Act (Canada) (the “ITA”) and the Excise Tax Act (Canada) the (“ETA”), including the right to acquire and inspect documentation, enter…
In the recent decision of Canada (National Revenue) v. Shopify Inc., 2025 FC 969 (“Shopify”), the Federal Court refused to authorize the Canada Revenue Agency (the “CRA”) to issue a so-called “unnamed person requirement” (“UPR”) to Shopify Inc. (the…