Information About Thorsteinssons’ Tax Blog

Yesterday, the Department of Finance announced GST relief for new residential rental construction.  In addition to signaling a reduction in the cost of supplying new rental homes, the measure potentially reduces or eliminates a major source of friction between developers and the Canada Revenue Agenc … Read more »

Context: As part of the avalanche of new draft legislation, the Department of Finance has released revised excessive interest and financing expenses limitation (EIFEL) rules.  The attached Excel is a high-level and technical summary of the new EIFEL regime.  The changes released last month are highl … Read more »

The recently enacted “flipped property” rules in the Income Tax Act (Canada) (the “Act”) have wide ranging implications. Several tax practitioners have written about the problematic nature of the rules (see, for example: Evan Crocker and Kenneth Keung, “Related-Party Transfers and the Flipped Proper … Read more »

When is an allocation of costs amongst supplies “fair and reasonable” for calculating input tax credits (“ITCs”)? In Marine Atlantic Inc. v The King (2023 TCC 95), the Tax Court confirmed that a “fair and reasonable” allocation: is based on the facts and supported by evidence; accurately reflects th … Read more »

The application of British Columbia’s provincial sales tax (“BC PST”) to digital services is controversial. A main issue has been whether the services should be taxed as “software”.  The British Columbia Supreme Court in Hootsuite Inc. v British Columbia (Finance), 2023 BCSC 358 (“Hootsuite”)  has p … Read more »