Information About Thorsteinssons’ Tax Blog

The Canada Revenue Agency (the “CRA”) is granted significant powers to gather information from persons under the Income Tax Act (Canada) (the “ITA”) and the Excise Tax Act (Canada) the (“ETA”), including the right to acquire and inspect documentation, enter premises, and question persons. The decisi … Read more »

In the recent decision of Canada (National Revenue) v. Shopify Inc., 2025 FC 969 (“Shopify”), the Federal Court refused to authorize the Canada Revenue Agency (the “CRA”) to issue a so-called “unnamed person requirement” (“UPR”) to Shopify Inc. (the “Shopify UPR”). A UPR is a type of requirement let … Read more »

In Seabridge Gold Inc. v British Columbia, 2025 BCSC 558, a recent case argued by Thorsteinssons LLP, the British Columbia Supreme Court held that expenses incurred to assess the economic viability of a mineral resource are eligible for the British Columbia mining exploration tax credit (“BC METC”) … Read more »

Introduction On March 26, 2025, the Tax Court of Canada (“TCC”) issued its decision in MEGlobal Canada ULC v. HMK. Following the recent decision of the Supreme Court of Canada (“SCC”) in Dow Chemical Canada ULC v. Canada., MEGlobal is another case confirming the TCC’s lack of jurisdiction over discr … Read more »

The BC Court of Appeal and the BC Supreme Court have issued two recent judgments regarding the application of the additional property transfer tax (“ATT”), commonly called the BC foreign buyers tax, imposed under the Property Transfer Tax Act, RSBC 1996, c 378 (the “PTTA”). In British Columbia v. 10 … Read more »