September 24, 2026
A proposal to introduce three new federal income tax brackets for high earners would generate an additional $4.5 billion in net federal revenue over the 2026-27 to 2030-31 period, according to an estimate released by the Parliamentary Budget Office on Sept. 22.
September 24, 2026
Part one of this series examined how the Federal Court of Appeal in Siam v. Canada, 2026 FCA 91 applied the Mpamugo v. The Queen, 2016 TCC 215 framework to a taxpayer’s claim that the Canada Revenue Agency (CRA) never sent his original Notice of Assessment.
September 24, 2026
I used to advise clients who were involved in shareholder disputes. I would always ask whether the shareholders had been less than angelic in their dealings with each other and the tax department. Although businesspeople tend not to judge people who only steal from the tax department to be all that bad, for the sake of simplicity I will refer to both shareholders who steal from each other, and shareholders who steal from the tax department, as crooks.
September 23, 2026
This is part one of a two-part series examining Siam v. Canada, 2026 FCA 91, in which the Federal Court of Appeal addressed a recurring evidentiary problem in tax reassessment litigation: what a taxpayer must actually prove when arguing that the Canada Revenue Agency never sent an original Notice of Assessment.
September 23, 2026
Since March 26, 2026, every reporting entity under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act must under the new s. 9.6(1.1) “ensure that the program is reasonably designed, risk-based and effective.” Its schedule entry is a very serious violation with a $20 million per violation ceiling for an entity ($4 million for a person). Little has been written about what s. 9.6(1.1) actually adds: an express program-level performance standard.
September 22, 2026
Prince Edward Island will move to dismantle a 35-year-old quasi-judicial tribunal and replace it with two new decision-making bodies that will continue to deal with various appeals and disputes.
September 22, 2026
In mergers and acquisitions (M&A) transactions, there is a constant struggle between the vendor and purchaser regarding risk allocation. This tension often arises from uncertainty regarding future performance, issues identified during due diligence and disagreements regarding value. One common mechanism for bridging that gap is an earnout, which makes part of the purchase price contingent on the post-closing performance of the target business.
September 21, 2026
The Carney government says its proposed “Building Canada Strong” legislation and supporting Cabinet directive will ensure that federal reviews and decisions on major project proposals are completed within one year of a “comprehensive” submission by the project’s proponents. The 243-page Building Canada Strong Act (Bill C-39) was introduced in the House of Commons Sept. 21 by Transport Minister and Government House leader Steven MacKinnon.
September 16, 2026
A behind-the-scenes bid by federal chief justices to make future recommendations from the federal independent judicial pay commission process binding on Ottawa is on hold as representatives of Canada’s 1,200 federal judges and Federal Court associate judges sue the Carney government for allegedly not giving “meaningful effect” to the work and non-binding advice of the latest quadrennial Judicial Compensation and Benefits Commission (Giardini Commission.)
September 15, 2026
Today, Prime Minister Mark Carney introduced the new Productivity Mega Deduction at the first Canada Investment Summit in Toronto. The tax incentive will increase the share of assets covered from 15 per cent to more than 65 per cent. He also announced that Canada will seek private investment through long-term concessions to operate the country’s four largest airports.