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On September 1, 2026, the Tax Court of Canada released its reasons in 2520356 Ontario Corp. v. The King, 2026 TCC 161, allowing a corporate taxpayer’s appeal from a GST/HST assessment of $126,100 on the sale of a Toronto property that had been gutted down to its foundation and studs, then abandoned mid-renovation, and sold “as is” at a substantial loss.

Canada has one of the largest tax treaty networks in the world. Its Canadian tax treaties are designed to prevent double taxation, allocate taxing rights between countries, and reduce Canadian non-resident withholding tax on cross-border dividends, interest, royalties, and similar payments.

A taxpayer who otherwise qualifies for the eligible dependant tax credit may still be prevented from claiming it if the taxpayer is legally required to pay child support for that dependant.