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Recent Posts
Below is a preview of the five most recent posts from the blog Thorsteinssons’ Tax Blog. To read these posts in their entirely or subscribe to future updates from this blog, please visit their website!
- The cost of inadvertent settlement offer disclosure: Technology Venture Corporation v The King
Overview The Tax Court of Canada Rules (General Procedure) provide that a party may be entitled to substantial indemnity costs if the party makes a settlement offer and ends up obtaining an outcome at trial as favourable as or more favourable than that offer. In Technology Venture Corporation v The … Read more »
- The taxpayer relief provisions: Accessing relief from penalties and interest
Overview Tax disputes generally hinge on whether the imposition of taxes and penalties is correct. However, there are situations where a taxpayer can be granted relief from the imposition of penalties and/or interest even if they were correctly levied. Subsection 220(3.1) of the Income Tax Act (“ITA … Read more »
- CRA publishes new policy document regarding information gathering powers
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 »
- Federal Court rejects CRA’s vague and inconsistent information request against Shopify Inc.
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 »
- Expenses to determine economic viability of a mine meet the purpose test and are eligible for the BC METC
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 »