Tax Disputes Resolution

Displaying 11-20 of 396

Retroactive changes to Saskatchewan PST applies to out-of-province online businesses

Saskatchewan imposes a 6% provincial sales tax (PST) on the retail sale or lease of most tangible personal property and taxable services (which includes software) consumed or used in the province. Where a sale of goods occurs in a brick-and-mortar...

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Canada Emergency Wage Subsidy: Revised rules for qualifying periods August through December

Bill C-20, An Act respecting further COVID-19 measures (“Bill C-20”), received Royal Assent on July 27, 2020. Bill C-20 enacts amendments to provisions of the Income Tax Act (Canada) that implement the Canada Emergency Wage Subsidy (“CEWS”). These amendments include...

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Is the Alberta advantage back?

The COVID-19 pandemic is having a devastating global economic impact. To boost the Alberta economy and attract more business, the Alberta Government has recently announced several measures. A. Repealing Residency Requirement for Directors U.S. and other foreign‑based businesses looking to...

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Miller Thomson represents CanLII in successful sales tax appeal

On July 17, 2020, the Tax Court of Canada found in favour of the Canadian Legal Information Institute (“CanLII”) (2020 TCC 56) on the basis that CanLII made a taxable supply with respect to the provision of a virtual library...

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Using anticipated losses within ownership structures

As much of Canada begins to loosen social restrictions surrounding Covid-19, many owners will be taking stock of the economic impact of the pandemic on their businesses. While the full economic picture is not yet known, many business are expected...

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Prescribed rate loans: Tax planning opportunity during uncertain times

The Canada Revenue Agency (the “CRA”) announced the prescribed rate for the third quarter of 2020 (“Q3”) on June 22, 2020. Starting July 1, 2020, the prescribed rate is 1% (reduced from 2% in the second quarter).  The prescribed rate...

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The Canada Emergency Wage Subsidy: A welcome assistance for employers – a pitfall for the unprepared

Introduction Canadians have been blindsided by the COVID-19 health and economic crisis. The impact has been swift, painful, and enduring. In March 2020 alone, Canada lost a record one million jobs. In the face of this crisis, Parliament passed legislation...

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To delay or not? Extensions by the CRA and the Tax Court of Canada

CRA has published its position on collections, audit, objections and appeals in light of the COVID-19 pandemic. Most noteworthy, CRA’s stated positions are the following: “Collections activities on new debts will be suspended until further notice, and flexible payment arrangements...

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Rent deferral during pandemic may not reduce GST/HST payable on rent

The COVID-19 pandemic has created unique dilemmas or opportunities for all aspects of society. While select businesses are proving to be uniquely successful during the economic downturn, most businesses are in need of assistance in order to continue to exist....

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Rebates on invoices: how to deal with GST and QST?

The current economic circumstances straining the liquidity of Canadian businesses will no doubt result in suppliers being required to grant rebates to recipients. This leads to the question as to whether suppliers are required to issue a credit note to...

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Displaying 11-20 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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