Tax

  • October 01, 2026

    Estate planning and Canadian citizenship by descent

    Many people may be surprised and pleased to learn that there is a new path to becoming a Canadian citizen. The Government of Canada passed Bill C-3, An Act to Amend the Citizenship Act (2025), on Dec. 15, 2025. Before this legislation came into effect, Canadian citizenship by descent was limited to the first generation born outside Canada. For example, Emily was born or naturalized in Canada, and she could pass her citizenship to her child, Duncan, born outside of Canada.

  • October 01, 2026

    New England Clean Energy Connect: Contract deficiencies and litigation issues

    The New England Clean Energy Connect (NECEC) contract’s central weakness is the absence of a workable structure for an energy-only transaction during system stress. The parties appear not to have established how an energy-only commitment should operate when the seller has inadequate energy, capacity or water reserves to serve all demands.

  • October 01, 2026

    New England Clean Energy Connect: Hydro-Québec’s resource position and planning history

    Hydro-Québec is a Crown corporation owned by the Quebec government. Unlike most U.S. utilities, its finances and policies are strongly shaped by the provincial government and the governing party’s policy objectives. Quebec has a regulatory agency, but it is also part of the provincial governmental structure.

  • September 30, 2026

    Exclusive: SCC’s Côté J. talks advocacy, key cases & rule of law as her 12th anniversary approaches

    Supreme Court of Canada Justice Suzanne Côté says she finds intervener advocacy on Zoom to be as effective as oral submissions made in the courtroom, but she is also alive to contrary arguments made by legal organizations, such as the Canadian Bar Association and The Advocates’ Society.

  • September 30, 2026

    Reviewing the New England Clean Energy Connect litigation filings

    On Sept. 8, 2026, the parties to the New England Clean Energy Connect (NECEC) agreements filed federal complaints concerning Hydro-Québec’s interruption of deliveries to Massachusetts during the first two months of the 20-year agreement.

  • September 29, 2026

    WeirFoulds welcomes associates Adam Nangini and Natasha Barrett

    Adam Nangini and Natasha Barrett have joined WeirFoulds as associates in its corporate and regulatory practice groups.

  • September 29, 2026

    Federal Court of Appeal clarifies rules for CRA requests for unnamed persons

    The lengthy decision in Canada (National Revenue) v. Zeifmans LLP, 2026 FCA 147 in part involves a detailed analysis of the legal concepts of abuse of process and improper collateral attack as well as the relevant decisions in Canada (Customs and Revenue Agency) v. Artistic Ideas Inc., 2005 FCA 68 and Redeemer Foundation v. Minister of National Revenue, 2008 SCC 46.

  • September 28, 2026

    Intergenerational business transfer capital gains exception: What the vendor gives up matters

    Section 84.1 of the Income Tax Act, the intergenerational transfer rules, has since 2024 contained a working exception for sales of a private company to a child’s corporation. Paragraph 84.1(2)(e) deems the vendor and the purchaser corporation to deal at arm’s length where the conditions of either ss. 84.1(2.31) or (2.32) are met, which switches off the deemed dividend and leaves the vendor with a capital gain eligible for the lifetime capital gains exemption — $1,275,000 for 2026. The conditions are not tax conditions. They are a statutory description of a vendor who has left the business, and the vendor’s counsel, not the accountant, is the one who has to make the client match it.

  • September 28, 2026

    Business valuations and M&A during tariff uncertainty

    The United States has launched tariffs under the Trump regime, and possibly future regimes, to counteract its decline as the world’s leading superpower. These tariffs impact valuation of any business engaged in global trade. To value such businesses, one must consider where the business operates, and whether that jurisdiction adjusted (i.e., Australia or Ireland, etc.), complied or negotiated a deal (i.e., the EU, Japan, U.K. and others), or retaliated (i.e., China or Canada).

  • September 25, 2026

    Co-founder terminations: The importance of good paper signed on incorporation

    Barry Anthony Cullain owned one-third of an Ontario elevator maintenance business and was its vice-president of operations. The other two shareholders each held a third. While an acquisition financing was closing, they proposed to buy his shares. The financing failed. They took him off the payroll and said he had retired.