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Tuesday, September 24, 2019 @ 10:27 AM

Timing liability under subsection 160(1) in Eyeball Networks case: Final analysis Clock with calendar

In the second part of this analysis of the Tax Court of Canada’s decision in Eyeball Networks Inc. v. Canada 2019 TCC 150, I conclude with an analysis of the TCC’s application of its interpretation of the meaning of the phrases “at the time” and “at that time” in subparagraph 160(1)(e)(i) of the Income Tax Act to the facts before the court. ... [read more]

Tuesday, September 24, 2019 @ 8:46 AM

Art as loan collateral: Export considerations art_collection_sm

This is the third in a series on utilizing your existing art collection as collateral. ... [read more]

Tuesday, September 24, 2019 @ 8:42 AM

FINANCE - Taxation - Real or immovable property assessment

Appeal by 994552 N.W.T. Ltd. from a decision of the Assessment Appeals Committee of the Saskatchewan Municipal Board pertaining to the 2016 municipal property tax assessments of two full-service hotels. ... [read more]

Monday, September 23, 2019 @ 12:01 PM

Tax lawyer returns to Langlois

Langlois lawyers announced that Maxime Chouinard has returned to the Quebec firm. ... [read more]

Monday, September 23, 2019 @ 9:28 AM

Notice of assessment: Should you pay in advance? Tax return with laptop glasses calendar

It is often the case that tax authorities audit a taxpayer for multiple taxation years. For example, tax authorities could start auditing a corporation today for its 2016, 2017 and 2018 taxation years. If, after having completed their audit, tax authorities believe the corporation has failed to declare the entirety of its revenue for more than one of those years, they could issue multiple notices of assessment against the corporation for all the relevant years under audit. ... [read more]

Thursday, September 19, 2019 @ 2:12 PM

Legal cross-fertilization at Supreme Court of Canada: Recent trends | Lawrence David

The Supreme Court of Canada (SCC) gives Canadians many reasons to be proud of its important work. For one, Canadians can boast about their Supreme Court being the only bilingual and bijuridical apex judicial institution in the world. Appeals are heard in English and French and, reflecting Canada’s legal diversity, from both the common law and civil law traditions. ... [read more]

Thursday, September 19, 2019 @ 9:04 AM

Access to Justice: New fund aiming at solutions | Beverley McLachlin

On Sept. 10, 2019, the Beverley McLachlin Access to Justice Fund was launched. The fund’s aim is to provide financing for innovative approaches to improving access to civil and family justice. Through an application process the Fund will allow individuals and organizations to explore, test, measure and grow good ideas that advance our progress. We will begin receiving applications next year, with a transparent and publicly available application process. ... [read more]

Thursday, September 19, 2019 @ 9:02 AM

Consequences of non-resident speculation tax Grass_home_percent_sign

The Non-Resident Speculation Tax (NRST) was introduced in the Ontario budget in 2017 as part of the provincial government’s measures to increase the affordability of housing. It applies to purchases of residential real property closing on or after April 21, 2017, when the property is located within the Greater Golden Horseshoe Region, which includes Toronto and Hamilton. ... [read more]

Wednesday, September 18, 2019 @ 9:13 AM

Timing liability under subsection 160(1) in Eyeball Networks case Clock and calendar

In Eyeball Networks Inc. v. Canada 2019 TCC 150, the Tax Court of Canada alerted tax planners to the pitfalls of issuing and cancelling a promissory note with nominal value in the context of a tax-neutral rollover under s. 85 of the Income Tax Act. This two-part series analyzes the Tax Court’s decision and its implications for tax practitioners. ... [read more]

Tuesday, September 17, 2019 @ 9:32 AM

New legislative changes to federal support enforcement laws Lawyer writing and court pillars

Through their enforcement efforts, federal, provincial and territorial governments disburse about $2 billion annually to Canadian families to satisfy outstanding support debts. At the federal level, it is estimated that approximately $185 million in support payments was garnisheed in 2017 and 2018 under the Family Orders and Agreements Enforcement Assistance Act. ... [read more]