Tax

  • July 07, 2026

    Tax transparency and procedural fairness: Lessons from King Charles’s disclosure for tax practitioners

    The King Charles tax disclosure creates no legal obligation in Canada and establishes no precedent that Canadian courts are required to follow. What it does is illustrate — at the level of a head of state — a principle that is deeply embedded in Canadian tax law and frequently litigated: that those who administer the tax system, and those who are subject to it, operate within a framework governed by the rule of law, institutional transparency and procedural fairness.

  • July 06, 2026

    Prime minister appoints new chief justices of the Ontario Superior Court of Justice & Federal Court

    Prime Minister Mark Carney has appointed new leaders to head two of Canada’s major trial courts. On July 6, Justice Alan Diner was appointed chief justice of the Federal Court, the national superior trial court that decides disputes in the federal domain. He succeeds Paul Crampton, who retired from the post Oct. 31, 2025.

  • July 06, 2026

    Federal Court remits LG interest-relief dispute to CRA, declines to make factual findings

    The Federal Court has declined to make findings of fact in a dispute over the Canada Revenue Agency’s (CRA) denial of LG Electronics Canada Inc.’s request for interest relief tied to a tax reassessment, finding that there were no circumstances warranting a departure from the usual remedy of sending the matter back for redetermination.

  • July 03, 2026

    Advisory board chair defends failure to shortlist at least 3 bilingual jurists for western SCC seat

    The chair of the advisory board that recommended ex-Manitoba Court of King’s Bench Chief Justice Glenn Joyal and one other unnamed jurist for appointment to the Supreme Court of Canada defended the board’s decision not to shortlist three to five names, which was contrary to the mandate from Prime Minister Mark Carney.

  • July 03, 2026

    CRA enforcement, non-resident obligations and voluntary disclosure path: The tax lawyer’s World Cup endgame

    This article addresses the enforcement architecture through which the CRA will identify and pursue non-compliance, the cross-border and non-resident tax obligations that arise from the World Cup’s international character, and the remediation pathways available to tax clients who did not report correctly, and what Canadian tax lawyers and accountants need to know before advising them on those pathways.

  • July 02, 2026

    Not from a source — or is it? How gambling, ticket resales and side hustles at FIFA World Cup are taxed

    Beyond short-term rental income, the 2026 FIFA World Cup will generate a wide variety of income-earning opportunities for Canadian residents, sports bettors, ticket resellers, parking space operators, food vendors, content creators, and transportation providers among them.

  • June 30, 2026

    Landlords’ tax trap during 2026 FIFA World Cup: Principal residence, change-in-use, GST/HST and s. 67.7

    The 2026 FIFA World Cup, jointly hosted by Canada, the United States and Mexico, will bring millions of visitors to Toronto and Vancouver and generate an extraordinary surge in short-term rental income for Canadian homeowners near those venues.

  • June 30, 2026

    Charitable gifts and the cy-près doctrine

    If you intend to make, or have already made, charitable gifts in your will, there is an interesting aspect of charitable giving that you may not have considered. What happens if the charity you named no longer exists, cannot receive the gift, or circumstances have changed such that your gift cannot be carried out as intended? In certain circumstances, the cy-près doctrine may preserve the gift and ensure that your charitable intentions are honoured.

  • June 30, 2026

    Long-term commercial leases in Quebec: Developments concerning land transfer duties

    For those involved in commercial real estate in Quebec, and in particular in helping commercial landlords and tenants under long-term leases deal with Quebec’s land transfer tax regime, and deal with Quebec’s voluntary disclosure regime for missteps in land transfer tax compliance, there are some noteworthy developments in 2026, briefly referred to below.

  • June 29, 2026

    King Charles and the tax protesters: Why every argument fails in Canadian courts

    The voluntary nature of King Charles’s tax payments has already attracted misuse by tax protesters, who argue by analogy that if taxation is voluntary for the monarch, it must be voluntary for all. This argument has no validity under Canadian law. It is, however, only the latest iteration of a broader family of pseudolegal commercial arguments that Canadian courts have been rejecting for decades.

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