Transfer Pricing 2023 – Canada: Law & Practice and Trends & Developments
Chambers Global Practice Guides: Transfer Pricing
David Chodikoff, Andrew Etcovitch, Carolyn Inglis, Daniel Kiselbach, Shashi Malik, Victoria Rodrigues and Marie-Hélène Tremblay are contributors to the 2023 edition of Chambers Global Practice Guides: Transfer Pricing. Both law & practice and trends & developments are highlighted in this...
Before setting off on the yellow brick road of tax controversy, do you know where it leads?
Dealing with tax authorities can be very distressing for taxpayers. Correspondence from the tax authorities often contain deadlines which are easy for the taxpayer to miss. In a recent Tax Court of Canada decision, Osadchuck v. The King, 2023 TCC...
2023 Canada Federal Budget: A Summary
Canada’s Minister of Finance (and Deputy Prime Minister) tabled Canada’s federal budget for 2023 (“Budget 2023”) on March 28, 2023 (“Budget Day”). While there is good news insofar as Budget 2023 does not propose any increases in tax rates or...
The new Underused Housing Tax: Are you tax exempt?
The Underused Housing Tax (the “UHT”) is a new annual 1% tax payable by an “owner” (other than an “excluded owner”) of “residential property”. A “residential property” includes, among other things, a detached house, a duplex, a triplex, a row-house...
Minimizing tax losses: The Solana hack
Throughout the year, many blockchains have been attacked by hackers. These loss events are indicators of the significant losses the cryptocurrency market has experienced. For investors who have suffered, an important consideration is how to utilize these losses. Accordingly, this...
The reasonableness of reasonable
The word “reasonable” has been part of Canadian tax lexicon for over a century. The 1917 Income War Tax Act allowed at para. 3(1)(a) a deduction in the computation of income for “such reasonable allowance as may be allowed by...
Selling your partnership interest? The possible impact of subsections 100(1) and (2) of the Income Tax Act
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Canadian individuals and corporations may have an underused housing tax filing obligation even when no tax is owed
Editor note: On March 27, 2023, the Canada Revenue Agency announced that “no penalties or interest will be applied for UHT returns and payments that the CRA receives before November 1, 2023”. This announcement effectively extends the filing and payment...
Trust planning and the notifiable transaction rules: Where do we go from here?
In 2022, the Department of Finance released draft legislation that includes, as part of a new regime of mandatory reporting rules, the notifiable transaction rules (“Rules”). The Rules are set to apply in a wide range of tax planning areas,...
Minimizing tax losses: The TerraUSD and LUNA collapse
Throughout the year, many cryptocurrencies have collapsed. These loss events are indicators of the significant losses the cryptocurrency market has experienced this year. For investors who have suffered losses, an important consideration is how to capitalize on these losses. Accordingly,...
