Tax

  • September 02, 2026

    How escalation actually works under Canada’s anti-money-laundering penalty regime

    One provision of Canada’s anti-money-laundering penalty regime is quoted more often than it is read. Section 4(2) of the Administrative Monetary Penalties Regulation provides that a series of minor violations identified on a notice of violation “shall be considered to be a serious violation” where the penalties total $400,000 or more. That sentence has appeared, in substantially that form, in law firm bulletins, compliance explainers and vendor guides published since the regime was overhauled in March 2026.

  • September 01, 2026

    Federal Court of Appeal overturns tax ruling on $89.8M mall sale

    The Federal Court of Appeal has overturned a finding that a property company was liable for a subsidiary’s potential tax debt arising from a structured $89.8-million mall sale, finding the Tax Court unfairly rejected the property’s undisputed value and wrongly concluded that the seller received a premium.

  • September 01, 2026

    Entrepreneur immigration files: When the business plan and financial evidence don’t reconcile

    Entrepreneur immigration files often contain two narratives. One is commercial: the business plan explains what the applicant intends to establish, acquire or operate. The other is financial: bank statements, tax records, corporate documents and transaction histories explain where the applicant’s capital came from and what funds are actually available. Problems arise when those narratives are reviewed separately and do not reconcile.

  • August 31, 2026

    Court upholds former Blue Jays’ exclusion of RCAs from Canadian taxable income

    The Federal Court of Appeal has dismissed a Crown appeal involving former Toronto Blue Jays stars Russell Martin and Josh Donaldson, affirming that the players correctly excluded contributions to their retirement compensation arrangements (RCAs) from their Canadian-sourced income for tax purposes.

  • August 31, 2026

    Can tariffs excuse performance of a commercial contract in Ontario?

    On Aug. 22, the United States imposed 50 per cent tariffs on a broad list of Canadian goods under s. 338 of the Tariff Act of 1930, which is a provision essentially unused for the better part of a century.

  • August 31, 2026

    A minute about minutes and professional ethics

    I was doing annual minutes for my teeny tiny corporation today, and I got to thinking.

  • August 28, 2026

    Canada highlights 50% counter-tariffs, $7.5B in support for businesses and workers

    As of Sept. 8, Canada will impose counter-tariffs of 15, 25 and 50 per cent on products drawn from the list of those targeted by U.S. tariffs, with the rate for each product matching the corresponding U.S. rate. The number of tariffed goods has dropped by nearly 200, from over 800 to now 629.

  • August 27, 2026

    Counsel should check that trial transcripts filed on appeal aren’t AI-created fakes, lawyer advises

    As AI-generated court filings by self-represented litigants proliferate, appellate counsel should read trial transcripts that are ostensibly “certified” more closely than ever and do so earlier in the appeal process as they might be AI-created fakes, advises a senior family law practitioner.

  • August 26, 2026

    Labour, NDP back tariff response, seek more support as Conservatives warn of costs

    Labour unions and the NDP are backing Ottawa’s response to new U.S. tariffs while calling for stronger worker supports, as business groups and Conservatives urge the government to minimize the counter-tariffs’ costs for Canadian businesses and consumers.

  • August 25, 2026

    Amanda Heale joins Torys’ tax team

    Amanda Heale has joined Torys as a partner in its tax practice in Toronto.

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