Canada: Income Tax

A bare trust is generally an arrangement in which the trustee holds only legal title to property and acts purely as the beneficiaries’ agent, with no independent discretion over it.

The Tax Court strikes the CRA’s attempt to plead a foreign accrual property income theory that was never part of the original tax reassessment, reaffirming firm limits on what subsection 152(9) permits.

Russell Porisky, founder of the Paradigm Education Group, was sentenced in 2016 to five and a half years in jail and a $259,482 fine for counselling fraud and tax evasion. His co-accused and common-law spouse, Elaine Gould, received a related sentence for her own tax evasion conviction.

Canada has introduced the Productivity Mega Deduction, a permanent tax incentive allowing immediate expensing for most depreciable property and Canadian development expenses. How will this policy shift Canada's competitive position for business investment, and what strategic considerations should taxpayers evaluate when claiming these enhanced deductions?

On July 2, 2026, the Canada Revenue Agency (CRA) published its updated Guidance on the Common Reporting Standard (Updated CRS Guidance).

Canada's proposed Productivity Mega Deduction would allow businesses to immediately write off the full cost of newly acquired capital assets, including aircraft and flight simulators, rather than spreading deductions over multiple years. This permanent change to the capital cost allowance regime could significantly benefit the business aviation industry, though taxpayers must carefully consider timing, income requirements, and documentation to maximize the deduction's value.

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

Free tokens are rarely free of tax consequences. Airdrops, staking rewards, yield-farming distributions and DAO compensation all arrive in a crypto wallet without a purchase, which makes them easy to overlook at filing time, and difficult to characterize when they are not overlooked.

When the Canada Revenue Agency (CRA) concludes that a GST/HST registrant’s books and records do not provide a complete or reliable picture of its taxable sales, it may reconstruct those sales using an alternative or indirect audit method.