Canada: Tax Authorities

If you have signed, or are about to sign, an agreement to buy a newly built home in Ontario, the HST you recover could be anything from nothing to $130,000. The difference usually comes down to a signing date, a price threshold, or whose name is on the purchase agreement, and not to whether you are buying your first home.

When the Canada Revenue Agency overhauled the Voluntary Disclosures Program (VDP) effective October 1, 2025, replacing Information Circular IC00-1R6 with IC00-1R7, it left tax practitioners with a long list of practical questions.

Canada’s tax system is a system of self-reporting. This feature is explicitly stated in subsection 150(1) of the Income Tax Act. This subsection requires taxpayers to file a tax return “without notice or demand for the return, for each taxation year of a taxpayer.”

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.

On September 15, 2026 (“Announcement Day”), the Department of Finance released draft legislative proposals to implement the “Productivity Mega Deduction,” permanent 100% first-year (“immediate”) expensing for a wide range of new or used depreciable property and for Canadian development expenses (“CDE”)...

The Federal Court’s June 12, 2026 decision in Minister of National Revenue v KPMG Canada LLP, T-139-26, is a significant ruling on the limits of privilege assertions by third-party tax advisors in the context of CRA audits.

The Canada Revenue Agency has confirmed that tax audits can be settled before completion, but significant cases require multiple layers of internal review and approval. Understanding CRA's internal settlement processes, including the role of the Audit File Resolution Committee, can help businesses develop effective strategies for resolving disputes efficiently and avoiding costly objections.

Canada's Prime Minister Mark Carney has unveiled the "Productivity Mega Deduction," a permanent tax measure providing immediate 100% write-offs for approximately 65% of business assets, positioning Canada's marginal effective tax rate on new business investment at 6.4% - the lowest among major economies. Alongside this initiative, the Canada Revenue Agency will now prioritize advance income tax rulings for investments exceeding $1 billion, aiming to deliver decisions within 90 business days to accelerate ma

The Canada Revenue Agency has announced a new priority system for advance income tax ruling requests, targeting investments of at least $1 billion in Canada. This initiative aims to accelerate the tax certainty process for major investors by reducing processing times and providing binding guidance on how specific Income Tax Act provisions apply to proposed transactions.