Overview – A Landmark Warning to CRA on Tax Litigation Conduct In Choptiany et al. v. The King (2022 TCC 112), the Tax Court of Canada delivered one of the most striking procedural rebukes against the Canada Revenue Agency (CRA) and the Department of Justice. The case involved three...
RESP Withdrawals: What Every Contributor and Beneficiary Should Know About Taxes A Registered Education Savings Plan (RESP) is a government-supported savings vehicle that helps Canadians set aside funds for the post-secondary education of their children or other eligible beneficiaries. Despite its popularity, many Canadians—including both contributors and beneficiaries—remain unclear...
Have You Made a Mistake on Your Tax Return? Here Is How to Correct It. It is not uncommon for individuals to file their taxes and then realize they have made a mistake. Perhaps a slip arrived late and was not included in the return, some income was accidentally...
Introduction – GAAR, Surplus Stripping and the Use of PUC Averaging The general anti-avoidance rule (GAAR) in section 245 of the Income Tax Act is designed to prevent taxpayers from obtaining tax benefits through transactions that, while compliant with the literal wording of the Act, frustrate its object, spirit,...
Introduction The Canada Revenue Agency (CRA) recently announced its 100-Day Service Improvement Plan, running from September 2 to December 11, 2025. This initiative comes after months of mounting criticism about slow call centre response times, processing backlogs, and general difficulties Canadians have faced when dealing with the Agency. The...
Overview On April 22, 2025, the Judicial Committee of the U.K. Privy Council released its decision in Methanex Trinidad v. Board of Inland Revenue ( UKPC 20). The ruling overturned earlier judgments of Trinidad and Tobago’s Tax Appeal Board and Court of Appeal, both of which had upheld withholding...
Taxpayer Relief and the Limits of CRA’s Discretion Subsection 220(3.1) of the Income Tax Act authorizes CRA to waive or cancel interest and penalties when fairness requires. The CRA applies this provision through its taxpayer relief program in accordance with Information Circular IC07-1R1, Taxpayer Relief Provisions (August 18, 2017)....
Introduction The Federal Court’s recent decision in Spennie Holdings Inc. et al v. Attorney General of Canada (T-1197-25, released August 15, 2025) reaffirms established Canadian tax law. Taxpayers cannot circumvent the statutory appeal process in the Tax Court of Canada by filing judicial review applications in the Federal Court. This ruling...
Understanding the Departure Tax: A Guide for Canadians Leaving the Country Moving out of Canada is not always as simple as packing your bags and settling in a new country. For many individuals, it can lead to unexpected tax consequences—most notably, the departure tax. The departure tax arises from...
Canada Strengthens Mandatory Disclosure Rules: What You Need to Know On June 22, 2023, the Income Tax Act was amended to enhance Canada’s mandatory disclosure rules, which are contained in Sections 237.3 to 237.5. These enhanced rules are designed to provide the Canada Revenue Agency (CRA) with earlier and...