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...
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...
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...
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...
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...
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...
Molly Luu quoted in Toronto Star article on COVID-19 bailouts for tax-haven companies
Toronto Star, "Justin Trudeau’s position on COVID-19 bailouts for tax-haven companies gets murkier"
The article examines whether companies registered in tax havens should be excluded from receiving COVID-19 bailout funds: There are too many unanswered questions about how the government would exclude companies from receiving bailout funds, said Molly Luu, a tax lawyer...
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...
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....
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...