Tax
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October 02, 2025
Court rules Husky Energy failed to withhold required tax on $329M non-resident dividend
The Federal Court of Appeal has upheld a finding that Husky Energy improperly failed to withhold 25 per cent of nearly $329 million in dividends paid to Luxembourg corporations, finding that they were temporary custodians for the majority shareholders.
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October 02, 2025
Line crossed: IRCC’s proposed administrative monetary penalties should alarm all Canadian bars
The federal government is quietly implementing a regulatory framework that should alarm every lawyer in Canada, regardless of practice area. Under the guise of addressing immigration “ghost consultants,” Immigration, Refugees and Citizenship Canada (IRCC) has crafted administrative monetary penalties (AMPs) that grant it unprecedented authority to discipline lawyers — the same lawyers who routinely challenge that department’s decisions in court.
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October 01, 2025
Court denies tax appeal of farming claim where physician-farmer sought losses
The Federal Court of Appeal has dismissed an appeal in a case where an individual who was both a physician and a farmer applied for a farming loss rule pursuant to 31(1) of the Income Tax Act and was denied.
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September 30, 2025
Tax considerations for a small business sale
The sale of a business can be done in two ways: either by way of asset sale where the business’s assets are sold, effectively rendering the business an empty shell that only exists on paper, or by share sale where the assets, contracts and licences remain in the business, but the ownership transfers to the buyer.
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September 30, 2025
AI, digital integration in small businesses could boost GDP by $12.8B: report
A new report by the Canadian Federation of Independent Businesses (CFIB) has found that while 92 per cent of small businesses in Canada are using digital tools for their business, only 10 per cent have fully integrated them across operations.
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September 29, 2025
What the reversal of the digital services tax means for your client’s business
If your client was getting their business ready for a major digital services tax (DST) payment on June 30, 2025, they’re off the hook. On June 29, the government of Canada announced that it would not move forward with the controversial DST.
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September 26, 2025
Ontario opening of the courts ceremony highlights digitization, reform of Rules of Civil Procedure
On Sept. 25, judges, attorneys general, leaders of law associations and others met for Ontario’s opening of the courts ceremony, discussing various strategies that have been and will be undertaken to improve access to justice. This included digitization and reformation of the Rules of Civil Procedure.
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September 25, 2025
Is it or isn’t it? FCA weighs in on compliance of $300M RRSP
A registered retirement savings plan (RRSP) is structured to allow eligible Canadians to accumulate income tax-free in an account. Withdrawals are taxable but can be made at a relatively low tax rate compared to that paid for investments outside an RRSP. The account is meant to facilitate investment for retirement purposes and considerable tax savings can be realized.
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September 23, 2025
Getting to ‘yes’: Settlement approvals for persons under disability
No settlement involving a person under disability, which includes the elderly incapable of managing their property and personal care, is binding on that incapable person unless the court approves of the settlement. That is because, while settling disputes before a hearing is encouraged by our judicial system, the legislature also recognizes that the incapable person would not have been able to properly consent to the settlement, and the court ought to review settlement for appropriateness to safeguard the incapable person’s interests.
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September 23, 2025
No benefit of hindsight: Ontario Court of Appeal clarifies framework for rectification
Rectification is an equitable remedy that corrects mistakes in written agreements. The recent case from the Ontario Court of Appeal, Pyxis Real Estate Equities Inc. v. Canada (Attorney General), 2025 ONCA 65, provides an important reminder of how rectification operates in the tax context and the importance of obtaining good tax advice.