Articles 2024

This article offers a legislative suggestion for promoting the development of purpose-built rental housing in Toronto.

This article discusses tax issues that can arise in respect of executor compensation and presents an important planning tip.

This is the second 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 the tax profession. In this quarter, we feature Laura White, a retired partner from Borden Ladner Gervais LLP.

Both the TCC and the FCA agreed with the basic proposition that a duly executed settlement agreement between the CRA and a taxpayer must be adhered to by the parties. The CRA was unable to resile from their settlement.

The process for tax remission can be celebrated for its flexibility in addressing unforeseen circumstances that affect specific taxpayers. Making a request for remission should not be overlooked on the appropriate facts.

On December 5, 2019, the Supreme Court of Canada dismissed the taxpayer’s leave to appeal in Van Steenis v Canada, 2019 FCA 107, an interest deductibility case where the taxpayer borrowed money to purchase mutual fund units, which he did not dispose of, but used returns of capital from those units for personal purchases.

This article discusses the proposed amendments to the employee life and health trust regime in the Income Tax Act, introduced on May 27, 2019. The changes to the current regime are outlined, as well as the proposed new rules to facilitate conversions of health and welfare trusts into employee life and health trusts

The FCA clarifies that section 16.2 of the Tax Court of Canada Act does not prohibit partners from continuing appeals on issues that were raised but discontinued by the partnership.

This is the first 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 the tax profession. In this quarter we feature a Q&A with Kathleen Penny, a well-regarded and brilliant partner at Blake, Cassels & Graydon LLP.

In Kufsky v. The Queen, the Tax Court of Canada upheld a section 160 tax assessment of a shareholder who received a dividend from a non-arm’s length corporation. This article provides an overview of the case’s key facts and the Court’s decision.