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Thorsteinssons LLP is Canada’s largest law firm practicing exclusively in taxation law. Our lawyers are consistently recognized as being among…
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Thorsteinssons LLP | Canada | 21 Jul 2021

Bill C-208 - Department of Finance confirms ITA amendments are in force and modifies its intended approach

On June 29, 2021, Bill C-208 received Royal Assent. As previously discussed, that Bill amended the federal Income Tax Act (the “Act”) with the…
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Thorsteinssons LLP | Canada | 16 Jul 2021

New Toronto vacant home tax coming January 1, 2022

On July 15, 2021, Toronto City Council approved a plan for implementing a new tax on the city’s vacant homes beginning in 2022. The proposed tax…
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Thorsteinssons LLP | Canada | 15 Jul 2021

Derivative liability tax assessments: A review of recent developments

Section 160 of the Income Tax Act (Canada) (the Act) is a collection tool that the Canada Revenue Agency (CRA) may use to collect unpaid tax debts of…
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Thorsteinssons LLP | Canada | 14 Jul 2021

Zeifmans - Request for information on unnamed persons issued to accounting firm

In Zeifmans LLP v. MNR, 2021 FC 363, the Federal Court considered whether a requirement for information regarding unnamed persons issued to an…
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Thorsteinssons LLP | Canada | 5 Jul 2021

Federal Court of Appeal confirms trust deed gave public corporation de facto control over a private corporation wholly owned by the trust

In Bresse Syndics Inc. v. The Queen, 2021 FCA 115 (sub nom. CO2 Solution Technologies Inc.), the Federal Court of Appeal (“FCA”) considered the extent…
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Thorsteinssons LLP | Canada | 2 Jul 2021

Federal Court finds CRA incorrectly conflates amending an election with rectification

In Brent Carlson Family Trust v. Canada (National Revenue), 2021 FC 506, two family trusts made requests to amend elections for the 2014 taxation…
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Thorsteinssons LLP | Canada | 29 Jun 2021

Documents requested pursuant to a requirement for information under s. 288(1) of the Excise Tax Act (Canada) need not be proportional to matter at issue

In Canada (National Revenue) v. 2276230 Ontario, 2021 FC 242, the Federal Court granted a compliance order to the CRA citing the Federal Court of…
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Thorsteinssons LLP | Canada | 25 Jun 2021

Senate Passes Significant Tax Bill Aimed at Facilitating Intergenerational Business Transfers

On June 22, 2021, the Senate passed Bill C-208 (following its previous passage in the House of Commons). A Private Members’ Bill, Bill C-208 is aimed…
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Thorsteinssons LLP | Canada, European Union | 18 Jun 2021

CRA Updates Guidance on Competent Authority Assistance

On June 1, 2021, the CRA published Information Circular IC71-17R6 (“IC71-17R6”), which provides guidance on obtaining assistance under a mutual…
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Thorsteinssons LLP | Canada | 11 Jun 2021

Leonard - Tax Court finds that distressed-debt transaction was an adventure or concern in the nature of trade

The Tax Court’s decision in Leonard v. The Queen, 2021 TCC 33, analyzed the oft-discussed legal concept of “an adventure or concern in the nature of…
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