Tax
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March 04, 2026
Federal Court of Appeal overturns Tax Court on GAAR and non-CCPC planning in Canada v. DAC
On Feb. 20, the Federal Court of Appeal released its decision in Canada v. DAC Investment Holdings Inc., 2026 FCA 35 (DAC), overturning the Tax Court of Canada’s conclusion that a corporate continuance undertaken to exit the Canadian-controlled private corporation (CCPC) regime did not constitute abusive tax avoidance.
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March 03, 2026
Key considerations when using alter ego trusts for estate planning
When assisting clients aged 65 and older with estate planning, alter ego trusts merit consideration as a means to reduce estate administration tax and facilitate the transfer of assets on death. There are a number of benefits associated with the use of alter ego trusts; however, it is also important to be aware of these trusts’ complexity and potential tax consequences. This article reviews the core features of alter ego trusts, how they are taxed and examines who may benefit from using them.
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March 03, 2026
OECD updates permanent establishment guidance for remote and hybrid work
On Nov. 19, 2025, the Organization for Economic Co‑operation and Development (OECD) released updates to the Model Tax Convention and its commentary, introducing an express analytical framework for assessing when a remote employee’s home office may constitute a “permanent establishment” (PE) of their employer in another jurisdiction. These changes are particularly relevant for organizations with cross-border remote or hybrid work arrangements.
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March 02, 2026
Court quashes CRA relief denial tied to lawsuit timing
The Federal Court has quashed a CRA decision denying taxpayer relief from interest and penalties on unmet tax obligations, finding that the minister’s delegate unreasonably concluded that litigation initiated by the applicant was unrelated to its non-compliance.
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March 02, 2026
Assessing Ontario tax increases, deadlines and relief options
Property owners in Toronto and across Ontario face a number of important developments in 2026 that may impact their tax obligations. This bulletin outlines the City of Toronto’s proposed tax rate adjustments, notes important deadlines for tax relief applications and provides guidance on managing Ontario’s property tax obligations in the coming year.
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February 26, 2026
Ottawa tables $502.8B Main Estimates for 2026-27 with higher defence, debt spending
The federal government has tabled the Main Estimates 2026-27 in the House of Commons, outlining $502.8 billion in planned budgetary spending for the upcoming fiscal year, including $230.4 billion yet to be approved by Parliament.
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February 26, 2026
Manitoba increases venture capital tax credit to $30M
The Manitoba government is increasing its Small Business Venture Capital Tax Credit to $30 million from $22 million to stimulate private investment and speed up growth of early-stage and scaling companies.
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February 25, 2026
Court slams Human Rights Tribunal’s refusal to hear cases
The Ontario Divisional Court has dismantled a major pillar of the Human Rights Tribunal’s unfair drive to reduce its backlog by dismissing most claims without a hearing.
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February 24, 2026
Globalization complexity: Foreign beneficiaries, foreign estate taxes
The Canadian family is becoming increasingly global. One aspect of this is that our children and other family members increasingly work in other countries, sometimes staying after post-secondary education at a foreign college or university, forming relationships, including marriage, having children and settling in their new home jurisdiction. Others immigrate to Canada, leaving relatives and friends in their country of origin.
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February 24, 2026
Federal Court of Appeal rules foreign continuance to bypass CCPC tax regime abusive
The Federal Court of Appeal has held that the general anti-avoidance rule (GAAR) applies where a company re-registers outside Canada in order to avoid the anti-deferral tax regime for Canadian-controlled private corporations (CCPCs).