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November 06, 2026
Appeal by the Minister of National Revenue from a judgment of the Tax Court concerning the Independent Order of Foresters. The Income Tax Act exempted the Order from paying tax on its income, but the exemption did not apply to its taxable income from its life insurance business.
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November 05, 2026
Capping bank customers’ liability for unauthorized transactions, extending the ban on foreign ownership of residential real estate and an enhanced capital gains exemption — along with new and stiffer penalties for environmental and fisheries violations — are among the myriad legislative changes the Carney government has proposed in its second budget.
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November 05, 2026
Mirzaei began with a line in a computer log. In March 2026, in a case challenging the Canada Revenue Agency’s (CRA) refusal to give her a second review, our client received the CRA’s certified record of her file. One entry, dated Nov. 11, 2024, read: “This case has been automatically completed as a no-reply.” It was attributed to “BOT067G” (Applicant’s motion record, written representations, paras. 8, 10).
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November 04, 2026
On the afternoon of Aug. 7, 2026, our client in Watton v. Canada (Attorney General) (Federal Court file 26-T-352, Oct. 6, 2026) called the Canada Revenue Agency (CRA) four times. The calls lasted seven, eight, 16 and 48 minutes. In the last one, an agent told her something no one at the CRA had told her before: she should have gone to the Federal Court within 30 days.
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November 03, 2026
Part one of this series set out the current baseline of the Canada Revenue Agency’s information-gathering powers under ss. 231.1 and 231.2 of the Income Tax Act, and the two judicial limits that frame them: Canada (National Revenue) v. Cameco Corporation, 2019 FCA 67 on oral questioning, and Canada (Attorney General) v. Chambre des notaires du Québec, 2016 SCC 20 on solicitor-client privilege.
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November 03, 2026
The recent Canada Investment Summit generated significant discussion about Canada’s ability to attract new investment and support long-term economic growth. For foreign companies and investors evaluating opportunities in Canada, tax planning is not merely a compliance matter. It can affect deal economics, financing flexibility, cash repatriation, treaty access and exit value.
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November 02, 2026
Limited licence legal practitioners can “lighten the load” for lawyers — and in doing so allow for more people to access assistance, participants heard during a recent Law Society of Saskatchewan (LSS) webinar.
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November 02, 2026
The Canada Revenue Agency’s ability to gather information during a tax audit rests on two deceptively short provisions of the Income Tax Act: s. 231.1, the general power to inspect, audit or examine, and s. 231.2, the power to issue a requirement for information or documents.
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October 30, 2026
Auditor General of Canada Karen Hogan delivered nine performance audit reports to the House of Commons on Oct. 29. The reports cover topics including money laundering, procurement technology, public health, the dental care plan, import assessments, ammunition, thermal coal commitments, water monitoring and net-zero emissions.
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October 30, 2026
Part one of this series established that third-party-created tax debt is recovered administratively, by set-off and without any proceeding. Part two established that the relief provisions practitioners reach for first cannot cancel the principal of it. This closing part addresses what remains.
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October 30, 2026
A Canadian pay statement can be genuine and still prove the wrong point in a permanent resident (PR) residency case. The legal question is not simply who paid the worker abroad, but whether a qualifying Canadian business actually assigned that person to full-time work outside Canada on terms that meet the residency rules. Where the foreign role has no defined end or realistic Canadian position to return to, an employer’s letter may not resolve the problem.
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October 30, 2026
For generations, an estate trustee stepping into an administration has started with the paperwork in front of them: the will, the bank statements that happened to be lying around, the prior trustee’s inventory (if applicable). That starting point is not going away. But as estate trustees — and particularly neutral and succeeding trustees who inherit an administration someone else began — come under closer scrutiny, a question is emerging: is documented, independent verification of what the estate actually owns and owes becoming an expected part of the duty of inquiry?
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October 29, 2026
Canada must “prepare for all contingencies up to and including war and other worst-case scenarios,” Prime Minister Mark Carney announced as he unveiled his government’s plan to roll out a new national security strategy over the coming year to ensure that the country can “control its own destiny and is resilient in the face of daunting challenges.”
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October 29, 2026
On Oct. 29, the Government of Ontario issued its 2026 Economic Outlook and Fiscal Review, emphasizing its efforts to become “the most competitive, resilient and self-reliant economy in the G7.”
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October 29, 2026
Part one of this series (see below for link) set out how a third party creates a federal tax liability in a taxpayer’s name and why recovery proceeds administratively against the provisions described there.
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October 29, 2026
Appeal by Minister of National Revenue (Minister) from decision refusing an order compelling Zeifmans to comply with a requirement issued under the Income Tax Act.
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October 29, 2026
Let’s face it folks. Our legal system caters to the rich and, on occasion, the middle class. Most of society cannot afford good lawyers and are on their own navigating our legal system. There is a simple reason for this. Lawyers like to earn good money. It is impossible to do that serving clients who cannot afford to pay hundreds — or thousands — of dollars an hour.
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October 28, 2026
Ontario has announced that it is providing an $8-billion provincial tax relief measure over the next five years to lower the cost of business investment and permanently allowing businesses to immediately write off 100 per cent of the value of various assets.
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October 28, 2026
Appeal by Harvard Properties Inc. (Harvard) from the Tax Court judgment dismissing its appeal from an assessment under s. 160 of the Income Tax Act (Act), and cross-appeal by the Minister from the identification of the tax debtor.
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October 27, 2026
Where a tax debt was created by somebody else, through identity theft, coercive control (such as sex trafficking or human trafficking) or an unauthorized filing, the CRA’s ordinary dispute architecture does not work. The assessment is valid, the objection period has usually run out, the client’s own account is the weakest evidence available, and the money is already leaving her account every month. It is worth noting that 70 per cent of human trafficking victims are women and girls.
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October 26, 2026
The Tax Court’s treatment of a son added to title for mortgage financing revives an unresolved tension over s. 160, bare trusts and the value of legal ownership without beneficial ownership.
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October 26, 2026
An East Coast law school now has a “first-of-its-kind” clinic that assists people embroiled in federal tax disputes — and at the same time gives students a unique “experiential learning opportunity.”
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October 26, 2026
On Oct. 9, 2026, President Donald Trump wrote: “I have just concluded a highly successful discussion with President Vladimir Putin, of Russia, wherein it was agreed that Russia will immediately supply over 300,000 Tons of Diesel Fuel to the American and Global Marketplace, another 500,000 Tons during the month of November, and 1,000,000 Tons immediately thereafter.”
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October 23, 2026
For the first time in more than 50 years, the Court of Appeal for Ontario has updated its test for leave to appeal from a decision of the Divisional Court. In Knauff v. Ontario (Human Rights Tribunal), 2026 ONCA 653, a five-judge panel confirmed that the test for leave is whether the proposed appeal raises an arguable question of law or mixed law and fact that is of sufficient public importance to warrant consideration by the Court of Appeal.
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October 22, 2026
Ontario’s Workplace Safety and Insurance Board (WSIB) will decrease its average workplace injury insurance premium rate from $1.23 to $1.18 per $100 of insurable payroll in 2027, with more than 80 per cent of premium-paying businesses receiving a rate reduction, according to an Oct. 22 release.