Introduction – GAAR, Surplus Stripping and the Use of PUC Averaging The general anti-avoidance rule (GAAR) in section 245...
Read More
Introduction The Canada Revenue Agency (CRA) recently announced its 100-Day Service Improvement Plan, running from September 2 to December...
Overview On April 22, 2025, the Judicial Committee of the U.K. Privy Council released its decision in Methanex Trinidad...
Taxpayer Relief and the Limits of CRA’s Discretion Subsection 220(3.1) of the Income Tax Act authorizes CRA to waive...
Introduction The Federal Court’s recent decision in Spennie Holdings Inc. et al v. Attorney General of Canada (T-1197-25, released August 15,...
Understanding the Departure Tax: A Guide for Canadians Leaving the Country Moving out of Canada is not always as...
Canada Strengthens Mandatory Disclosure Rules: What You Need to Know On June 22, 2023, the Income Tax Act was...
Notice of Appeal filed after deadline In June 2025, the Tax Court of Canada (TCC) handed down the decision...
In Canadian tax law, members of a syndicate are generally treated the same when it comes to the tax...