Tax

  • 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.

  • June 16, 2026

    CUSTOMS AND EXCISE - Customs - Tariff classification - Imports - By type of product - Tools, equipment and instruments

    Appeal and application for judicial review by the Attorney General of Canada (Attorney General). This was from a decision of the Canadian International Trade Tribunal (Tribunal) classifying imported surgical gloves as articles for use in surgical instruments, thereby qualifying them for duty-free importation. Medline Canada Corporation imported various models of sterile surgical gloves and initially classified them as surgical gloves of vulcanized rubber.

  • June 12, 2026

    OnlyFans content creators, beware: CRA is watching (for income tax and GST/HST compliance, of course)

    OnlyFans is a subscription-based online platform that allows creators to earn income from digital content through monthly subscription fees, tips and pay‑per‑view interactions. Although frequently associated with adult content (sexually explicit), the platform is used by a wide range of creators, including fitness professionals, entertainers and social media influencers.

  • June 12, 2026

    FINANCE - Taxation - Real or immovable property assessment - Methods of assessment

    Appeal by Souris Valley Lodging Inc (“Souris Valley”) against a decision of the Assessment Appeals Committee of the Saskatchewan Municipal Board (“Committee”). A 2022 assessment of two hotel properties by the Saskatchewan Assessment Management Agency (“SAMA”) used the modified cost approach which required a determination of the Replacement Cost New Less Depreciation of the improvements and the application of a market adjustment factor (“MAF”) to calculate the value that was then added to the property (“Cost Approach”).

  • June 11, 2026

    Ombudsperson opens examination into delays in CRA processing of complex T1 adjustment requests

    The Taxpayers’ Ombudsperson has announced a systemic examination into “delays taxpayers are experiencing when the Canada Revenue Agency (CRA) determines that a T1 adjustment is complex.”

  • June 11, 2026

    Can taxpayers challenge CRA’s AI audit selection?

    Part one of this series (see below for link) examined the Canada Revenue Agency’s growing use of advanced analytics, risk-scoring systems and other technologies to help identify files for potential tax audit and compliance review.

  • June 10, 2026

    Top judge backs Jordan juggernaut, warns bar against filing fake AI-generated precedents in court

    The Supreme Court’s controversial Jordan decision, which has sparked the dismissal of thousands of cases due to unconstitutional trial delay, is still good law, but stays of proceedings are not a cure for undue systemic trial delay, Canada’s top judge says. “One stay of proceedings is too many,” Supreme Court of Canada Chief Justice Richard Wagner stressed at his annual press conference in Ottawa June 9.

  • June 10, 2026

    Court approves $1.95M settlement with cy-près payment to charity, not class members

    The Ontario Superior Court has approved a $1.95-million settlement of a proposed class action alleging BMO overwithheld taxes on withdrawals from registered retirement income fund (RRIF) accounts, finding that a cy-près payment to charity was justified because direct compensation to class members was impractical.

  • June 10, 2026

    Why U.S. title insurance and escrow matter to the Canadian real estate lawyer

    Canadian real estate lawyers are accustomed to handling closings end to end. Under Canada’s Torrens-style land titles systems, the government register provides statutory assurance of title, and closings largely involve inter-law-firm fund exchanges. When your client purchases real property in the United States, however, the process is fundamentally different. There is no government guarantee of title. Instead, title evidence and settlement are private-market functions performed by title insurers and escrow/settlement agents. Understanding these differences is essential to properly advising your client on a U.S. real estate acquisition.

  • June 09, 2026

    How CRA is using AI to target businesses, individuals for audits

    Artificial intelligence has become a popular topic in discussions about government administration, but the more important question for every Canadian tax lawyer and accountant may be considerably narrower: how much of the Canada Revenue Agency’s audit selection process is already driven by algorithms, risk scoring and advanced analytics?

  • June 08, 2026

    Aun Syed joins Procido LLP as associate

    Procido LLP has welcomed Aun Syed as an associate in its Saskatoon office.

  • June 05, 2026

    Inconsistent consequences: How Canadian courts and tribunals respond to AI misuse

    When a Canadian court or tribunal finds that a party has relied on a case that does not exist, the consequence is far from uniform. In one decision, the lawyer responsible was ordered to pay $17,550 in costs personally. In another, the order was $100. In 60 of the 177 decisions we reviewed, the adjudicator identified the problem but imposed no consequence at all.

  • June 04, 2026

    Tax Court reluctantly denies CCB claim, citing longstanding gap in law

    The Tax Court of Canada has “reluctantly” upheld a finding that a father who cannot be removed from Canada but is not a “protected person” under immigration law is ineligible for the Canada Child Benefit (CCB), noting he had fallen through a crack in the legal system that the court first identified nearly 25 years ago.

  • June 04, 2026

    Donating fine wine? Art? Software? Why the CRA is auditing overvalued gifts to charities

    The Canada Revenue Agency’s increasing scrutiny of charitable donation valuations continues to expand beyond traditional gifting arrangements involving art, pharmaceuticals and software.

  • June 03, 2026

    Canada plans to extend ‘key’ steel and aluminum tariff measures to June 2027

    Ottawa says it will extend for a year its steel tariff-rate quotas (TRQ) regime for imports from non-CUSMA partners and the existing horizontal tariff relief for eligible U.S. steel and aluminum products, and additionally, for eligible steel products subject to derivative tariffs.

  • June 02, 2026

    Taxpayers’ Ombudsperson to examine CRA complaint resolution options

    Taxpayers’ Ombudsperson François Boileau has begun a systemic examination of the options available to taxpayers who experience issues with the Canada Revenue Agency (CRA), and whether those processes are fair and efficient.

  • June 02, 2026

    Tax Court enforces GST/HST appeal settlement in Zhang v. The King

    The fundamental legal issue in the Tax Court of Canada decision of Zhang v. The King, 2026 TCC 71 (Zhang) relates to appellant motions to enforce a settlement reached with the respondent prior to a hearing.

  • May 29, 2026

    How CRA’s use of MLS data increases tax audit exposure for ‘property flippers’

    The Canada Revenue Agency is increasingly relying on Multiple Listing Service (MLS) data and other third-party information to support tax audits involving residential real estate transactions.

  • May 22, 2026

    2025 recorded execution count highest since 1981

    Amnesty International’s latest annual report on the global state of the death penalty paints a sobering picture.

  • May 21, 2026

    Legislative pathway for natural hydrogen: Nova Scotia’s Subsurface Energy Resource Extraction Act

    The province of Nova Scotia recently passed legislation that establishes the legislative framework for the development of a natural hydrogen industry in the province.

  • May 20, 2026

    Two stumbles forward, one back: Three wise men opine on Churchill Falls MOU after independent review

    Fifty-seven years ago, Hydro-Québec signed an advantageous contract with the Churchill Falls (Labrador) Corp. (CF(L)Co) for a large block of power at $2 per megawatt hour for 75 years. In December 2014, the premiers of Quebec and Labrador announced a proposed transaction for the existing dam plus 3,900-megawatt expansion products. Simultaneously, they released the Churchill Falls Memorandum of Understanding (MOU). The document was not really a memorandum of understanding; it was a pastiche of draft contract sections plus schedules that reflected modelled quantities and prices.

  • May 19, 2026

    Federal Court quashes ‘stream of consciousness’ CERB decision

    The Federal Court has set aside a Canada Revenue Agency (CRA) finding that an individual was ineligible for benefits under the Canada Emergency Response Benefit Act, ruling that the decision-maker’s reasons were “hardly” intelligible.

  • May 19, 2026

    Carney announces members of Independent Advisory Board to help select next SCC judge

    On May 19, Prime Minister Mark Carney announced the chair and members of the Independent Advisory Board for the Supreme Court of Canada Judicial Appointments.

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