Articles 2022

Manjit is a partner in the tax group at Miller Thomson. She received her law degree from the University of Toronto and was called to the Bar in 2000. Manjit advises on Canadian and cross-border tax matters to public and private companies, partnerships, trusts, private equity and infrastructure funds, pension plans and sovereign wealth funds.

Kathryn Walker discusses strategies for salvaging underwater stock options.

Randy Schwartz and Seth Lim report on the recent Tax Court case Zomaron Inc. v. The Queen (2020 TCC 35).

Under new Canada Emergency Wage Subsidy (“CEWS”) legislation, non-arm’s length parties which transact with each other using arm’s length terms – as often required by the Canada Revenue Agency (“CRA”) – are penalized unfairly. This is the result of a definition in the formula which erroneously refers to the “current reference period” when it should refer to the period immediately prior to the “current reference period."

This article provides a high level overview on the advantages of implementing an estate freeze when the value of businesses has declined due to the novel Coronavirus.

On April 17, 2020, the Department of Finance released legislative proposals to amend certain income tax measures intended to support Canadian journalism organizations (these measures were previously introduced in the 2019 Federal Budget). This article reviews and comments on the impact of the proposed legislative amendments.

The taxpayer successfully appealed to the FCA in Loblaw Financial Holdings Inc. v. The Queen, 2020 FCA 79. The FCA overturned the TCC’s decision to include over $473 million in the taxpayer’s income as foreign accrual property income.

This is the third installment of the OBA Tax Section's Q&A series with women lawyers in tax. The objective of this series is to give insight into the tax law career possibilities and practice areas that women can have, to give advice to junior tax lawyers or students who may be considering tax, and to shine the spotlight on women leaders in tax.

Ontario’s 2020 economic and fiscal update was delivered on March 25, 2020 and includes new measures that respond to economic concerns as a result of COVID-19.