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Canada Canada Revenue Agency (CRA) Tax Planning

Dickinson Wright

Tax Planning Misstep? Ontario Court of Appeal Says No to Rectification

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A recent decision from the Ontario Court of Appeal is a good reminder that courts won’t bail you out just because a tax plan didn’t go as expected. In Pyxis Real Estate Equities Inc. v. Canada, 2025 ONCA 65, the Court made it...more

Bennett Jones LLP

Turning Losses Into Gains: Private Equity Tax Strategies With Distressed Businesses

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Private equity (PE) firms play a critical role in revitalizing struggling businesses by providing, among other things, financial support and operational expertise. PE transactions are often driven by a combination of...more

Blake, Cassels & Graydon LLP

Tax Update: Proposed Increase to Capital Gains Inclusion Rate Deferred to 2026

On January 31, 2025, the Minister of Finance (Canada) announced that the proposed increase in the capital gains inclusion rate from one-half to two-thirds, previously intended to be effective for dispositions occurring on or...more

Stikeman Elliott LLP

Prorogation of Parliament and the Proposed Capital Gains Inclusion Rate Increase

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On January 6, 2025, Prime Minister Justin Trudeau announced his resignation as prime minister and the prorogation of Parliament until March 24, 2025. At the federal level, prorogation is an act by the Governor General,...more

Bennett Jones LLP

2024 Taxation Year Reporting Exemption for Bare Trusts

Bennett Jones LLP on

On October 29, 2024, the Canada Revenue Agency (CRA) announced that bare trusts are once again exempt from filing the T3 Income Tax and Information Return (including Schedule 15 regarding beneficial ownership information of a...more

Stikeman Elliott LLP

GST/HST Input Tax Credit Claims: Does the Supporting Documentation Need to be Issued by the Supplier?

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On June 9, 2022, the Tax Court of Canada (“TCC”) allowed CFI Funding Trust’s (“CFI”) appeal in relation with the input tax credits (“ITC”) it claimed for prepaid rent paid in connection with the securitization of automobile...more

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