Tax

  • July 14, 2026

    When 4 CRA ‘fairness’ reassessments meet appeal rights: Forrest v. The King

    The Tax Court of Canada’s recent decision in Forrest v. The King, 2026 TCC 121 gives tax lawyers a detailed map of what happens when the Canada Revenue Agency (CRA) reassesses the same taxation year four times, contradicting itself twice along the way, and then argues that the taxpayer has no right to appeal the last word.

  • July 13, 2026

    When home sales trigger GST/HST and builder status: Fadali v. Canada

    The Canada Revenue Agency (CRA) has spent considerable effort focusing on taxing GST/HST on home sales. If a taxpayer is considered to be a “builder” as defined in subsection 123(1) of the Excise Tax Act, R.S.C., 1985, c. E-15 (ETA), the respective income is treated as if on account of business and not capital. Therefore, GST/HST obligations apply. In Ontario, this means a taxpayer must charge 13 per cent GST/HST on the sale price and remit this amount to the federal government.

  • July 10, 2026

    Many trial judges overworked and stressed — but not as much as lawyers: new national survey

    Many federally appointed trial judges report stress from excessive workloads, limited control over their time in the workplace and too few support resources, according to a new national survey of judges’ physical and psychological health. On July 9, the Canadian Judicial Council (CJC) reported on extensive research commissioned from the Université de Sherbrooke between 2024 and 2026 by the council of 44 chief and associate chief justices.

  • July 08, 2026

    Arbitrage betting and Canadian tax law: When ‘risk-free’ profits become taxable

    Arbitrage betting, often described as “sure betting” or “arb betting,” has gained increasing prominence in Canada following the expansion of regulated single-event sports betting and the rapid growth of offshore and blockchain-based prediction markets.

  • July 07, 2026

    Vacation pay and the reasonable notice period: Where Canadian courts stand

    When a court awards damages in lieu of reasonable notice, should the award include vacation pay that would have accrued over the notice period?

  • July 07, 2026

    Feds launch consultations for Budget 2026

    The federal government has announced the launch of online and in-person consultations for Budget 2026 ahead of its delivery this fall.

  • 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.

  • June 29, 2026

    Tax Foundation CEO Heather Evans to lead CRA

    Prime Minister Mark Carney has appointed Heather Evans as commissioner of revenue, effective July 13, 2026.

  • June 26, 2026

    King Charles, the Crown, and Canadian Tax Law: What the royal tax disclosure actually means

    King Charles III has announced the public disclosure of the total amount of personal income tax he voluntarily paid to the British government: £12.9 million for 2024-2025. This figure was published as part of the annual Royal Household finances report released in June 2026. This is reported to be the first time a reigning British monarch has publicly quantified personal tax paid in a given year. 

  • June 25, 2026

    New Human Rights Tribunal of Ontario practice direction on jurisdiction must be reconsidered

    Earlier this year, the Divisional Court of Ontario found that procedures adopted by the Human Rights Tribunal of Ontario (HRTO) to determine its jurisdiction were unreasonable and contrary to law.

  • June 23, 2026

    Manitoba First Nations’ chiefs ‘wholeheartedly’ back C.J. Joyal’s nomination to Supreme Court of Canada

    The Assembly of Manitoba Chiefs has publicly weighed in on a Supreme Court of Canada nomination, stating they “wholeheartedly endorse” Manitoba Court of King’s Bench Chief Justice Glenn Joyal’s candidacy and are “confident he will bring fairness, wisdom and humility to Canada’s highest court.”

  • June 23, 2026

    Biggest overhaul in a decade? CSA proposes changes to bid and reporting regimes

    On May 14, 2026, the Canadian Securities Administrators (CSA) published a notice and request for comment in respect of a suite of proposed amendments to the issuer bid, take-over bid and beneficial ownership reporting regimes in Canada, marking the most significant set of changes in more than a decade.

  • June 22, 2026

    Manitoba King’s Bench Chief Justice Glenn Joyal nominated for Supreme Court western vacancy

    Manitoba Court of King’s Bench Chief Justice Glenn Joyal, widely reputed in recent years to be a leading candidate for appointment to the Supreme Court of Canada, has been nominated to fill the western vacancy that opened up with the May 30 retirement of Supreme Court of Canada Justice Sheilah Martin, Prime Minister Mark Carney announced on June 22.

  • June 19, 2026

    Lawyers know that rich people have problems, too

    I articled for the now defunct law firm of Goodman and Carr. It was a well-regarded firm in its day. Wolfe Goodman was a senior partner and a leading tax lawyer of his era. In my tax rotation, I spent considerable time with him. He made tax sound so interesting that there was even a brief moment in time that I thought I wanted to be a tax lawyer.

  • June 17, 2026

    Taxpayers’ Ombudsperson’s report finds surge in CRA complaints

    Taxpayers’ Ombudsperson François Boileau tabled his annual report in Parliament on June 12, which found a surge in complaints against the CRA compared to the last three fiscal years. The report also provided the Office of the Taxpayers’ Ombudsperson’s (OTO) recommendations.

  • June 16, 2026

    New private-sector privacy regulator to wield broad investigative & order powers, big penalties

    Ottawa has proposed a new legislative regime for private-sector privacy regulation that imposes a raft of obligations on how businesses and other non-governmental organizations handle Canadians’ personal data, with oversight from a robust dual privacy and digital harms regulator armed with audit and binding order-making powers, backed by hefty administrative monetary penalties (AMPs) and fines for the most serious new offences.

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