Canada: Tax

Robinson v Canada (Attorney General), 2026 FC 854 (Federal Court File No. T-1567-22) [Robinson] is a significant Federal Court decision for taxpayers, accountants, and advisors managing cross-border residence disputes

The perception that Internal Revenue Service enforcement is stronger than Canada Revenue Agency enforcement is common among taxpayers and advisors, particularly in cross-border contexts.

The Federal Court of Appeal has issued a significant ruling affecting the taxation of non-resident professional athletes in Canada. This decision provides important clarity on how tax obligations are determined for athletes competing across international borders. The ruling has implications for sports organizations, athletes, and tax practitioners dealing with cross-border employment taxation issues.

Cryptocurrency has become a significant source of wealth for many Canadians. Whether an individual holds Bitcoin as a long-term investment, actively trades digital assets, participates in staking programs, or engages in decentralized finance (DeFi), cryptocurrency can create unique estate planning challenges that do not arise with traditional investments.

The Federal alternative minimum tax (“AMT”) regime is intended to ensure that individuals, including certain trusts, pay a certain minimum level of tax where income tax calculated under the regular rules is reduced...

Recent amendments to Canada's Income Tax Act have extended the post-mortem loss carryback election from one to three taxation years, providing estate administrators significantly more time to implement tax planning strategies.

A transfer generally qualifies as a gift for Canadian income tax purposes where a person voluntarily transfers property he or she owns without receiving or expecting a disqualifying benefit or consideration in return.

When the holiday season approaches and the calendar year nears its end, many Canadians look to support the causes they care about while also managing their tax position.

Pleading guilty to a tax fraud charge is rarely the end of a taxpayer’s troubles. In Bernier v The King, a taxpayer who pleaded guilty to Income Tax Act and Excise Tax Act offences in 2022 tried, more than three years later, to reopen his case.

If you are a Muslim homebuyer weighing a halal mortgage against a conventional one, the product that keeps you offside your faith may still put you offside the taxman in ways a conventional mortgage never would.

The Canadian tax landscape experienced significant developments this summer, from expanded CRA audit powers and AI-driven compliance to new transfer pricing rules and evolving trade tariffs. These five key updates carry important implications for taxpayers and multinational businesses as they navigate an increasingly complex regulatory environment heading into fall.

The Canadian government has proposed significant technical amendments to the Income Tax Act's definition of "taxable Canadian property" (TCP), fundamentally altering how publicly traded partnership units are classified and expanding the look-through rules for determining TCP status. These changes, effective upon Royal Assent, will impact cross-border transactions and investment structures by broadening the scope of what constitutes TCP and reinstating historical rules for options and interests in property.