In Stern v. The King, 2026 TCC 131, the Tax Court accepted brokerage records, foreign tax information slips, and credible testimony as sufficient evidence to support a..
Day: July 14, 2026
Somerset Limited: Why a 1943 Corporation Remained a CCPC After a BVI Continuance
No — but not for the reason often assumed. In Somerset Limited v. The King, 2026 TCC 123, the Tax Court held that Somerset remained a Canadian-Controlled..
Liu v. The King: Limits on Using Subsection 152(9) to Add a FAPI Basis
In Liu v. The King, 2026 TCC 126, the Tax Court struck specific paragraphs from the Crown’s pleadings that advanced a Foreign Accrual Property Income (FAPI) basis..
Selling Shares of a Canadian Real Estate Company: The Treaty Risk for Non-Residents
Generally, no — in a recent technical interpretation, CRA confirmed that a Canadian corporation’s real estate used in a rental operation does not qualify for the “business..
Beneficial Ownership and Part XIII Withholding Tax: Lessons from C&W Offshore
Under Canada’s Part XIII withholding tax rules, beneficial ownership of a cross-border payment depends on who actually receives, controls, and bears the risk on that payment —..
When Does Building and Selling a Home Trigger GST/HST Builder Rules?
Yes — under the Excise Tax Act’s self-supply rules, a person can be a “builder” and owe GST/HST even without any history of professional development, if the..
Missed GST/HST Input Tax Credits: Can You Recover an Expired Claim?
Generally, no — subsection 296(2) of the Excise Tax Act is not a general tool for reviving an expired input tax credit (ITC) claim. It is narrower..