Tax Disputes Resolution

Displaying 1-10 of 396

E-Commerce Businesses – Do you need to be registered for GST/HST?

Effective July 1, 2021, major changes to the GST/HST regime as it relates to e-commerce and the digital economy came into effect. We previously reported on these measures when they were first announced in the Fall Economic Statement 2020 and...

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Budget 2021 – Tax enforcement, audits, and oral interviews

Recently, Chrystia Freeland, Deputy Prime Minister and Minister of Finance, presented the  2021 Budget on behalf of the Government of Canada (“GOC”). Debits and Credits. The cornerstone of any accounting textbook. For the federal government, the debits (spending) have not...

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Budget update – Sales, excise, and digital services tax

On April 19, 2021, the federal budget was tabled by Deputy Prime Minister and Finance Minister Chrystia Freeland (“Budget 2021”). Budget 2021 confirmed the measures first announced on November 30, 2020 in Supporting Canadians and Fighting COVID-19: Fall Economic Statement...

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What a non-resident vendor of goods needs to know about Canadian sales tax

When the federal goods and services tax (“GST”) was introduced in 1991, “Seinfeld” was on the air and most consumer goods were purchased at brick and mortar stores. Fast forward to 2021 and puffy shirts can be purchased online from...

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Expansion to BC PST registration and collection rules effective April 1, 2021

In Provincial Budget 2020, measures were announced that would require businesses not otherwise carrying on business in British Columbia (“BC”) to register for and collect PST. Amendments to the Provincial Sales Tax Act (British Columbia) (“BC PSTA”) were supposed to...

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COVID-19 relief for resource companies: Resource issuers may rely on proposed extensions

Resource companies that have issued flow-through shares shortly before or during the global COVID-19 pandemic may have faced difficulties, including the shutdown of mines, incurring eligible resource expenses within the normal timelines required under the Income Tax Act (Canada) (the...

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Proposed limits on employee stock option deductions

Introduction The long-standing tradition of using employee stock options to reward and retain employees in Canada is expected to change for some employees due to limits proposed by the federal government to the current advantageous tax treatment available to employees...

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Audit First, Pay GST/HST Tax Refunds (Much) Later

Canadian Tax Focus, Volume 10, Number 4, November 2020

GST/HST registrants who commonly make zero-rated supplies often file a return claiming a net tax refund, relying on the prompt payment of that refund in order to finance their businesses. The minister is required to pay the refund “with all...

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Appeals of Charity Revocations: What Is The Proper Standard?

Canadian Tax Focus, Volume 10, Number 4, November 2020

Until recently, when a charity challenged its revocation at the FCA, the charity had to prove that the CRA’s decision to revoke was unreasonable. It now appears that the charity must prove that the CRA committed a palpable and overriding...

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No appeal of tax court decision in CanLII v. MNR

The decision of the Tax Court of Canada in CanLII v. MNR will not be appealed by the Minister of National Revenue. The case was argued on behalf of the registrant CanLII (Canadian Legal Information Institute) by Miller Thomson partners...

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Displaying 1-10 of 396

COVID-19 Resources

We have written on a variety of topics to help identify the pertinent issues, understand the legal implications, minimize risk exposure and manage legal obligations.

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Successful Tax Court of Canada Appeal

David Chodikoff and Ron Choudhury represented CanLII in a successful sales tax appeal, where the Tax Court of Canada found in favour of CanLII, on the basis that CanLII made a taxable supply with respect to the provision of a virtual library and are consequently entitled to claim input tax credits.

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Leading tax lawyer

Proud to announce Partner David Chodikoff has been recognized as a ‘highly regarded’ practitioner in the area of tax controversy by International Tax Review’s Tax Controversy Leaders: Guide to the World’s Leading Tax Controversy Advisers.

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