As we will see shortly, it is often “better to give than to receive,” though this statement begs the obvious question of whether it is better to do so during one’s lifetime or upon one’s death. Many well-to-do individuals...more
Incentivizing construction of new rental homes is a key policy priority for Canadian governments. As discussed in an earlier post, the federal Department of Finance issued a news release on September 14, 2023 relating to...more
On April 16, 2024 (“Budget Day”), the federal government released its annual budget (“Budget 2024”), which includes certain sales and excise tax measures and also confirms the government’s intention to proceed with several...more
Earlier this week the White House released its Fiscal Year 2025 Budget. Of course, the federal government has not yet adopted a budget for the Fiscal Year 2024 even as we approach that year’s halfway mark. But I digress. The...more
Registration of Business Entities - Unless exempted, business entities must be registered with the Accounting and Corporate Regulatory Authority (ACRA) via their business filing portal: BizFile+. A foreigner residing...more
On January 1, 2024, the amounts that individuals can gift free of federal gift and generation-skipping transfer (GST) tax rose to $13,610,000 for individuals and $27,220,000 for married couples due to inflation adjustments....more
Gujarat International Finance Tec-City (GIFT City) was established in 2007 as India’s first operational smart city and an emerging global financial and IT services hub located in Gandhinagar, Gujarat. GIFT City is a personal...more
Key Facts of Real Estate Acquisitions Under Australian Law - INTRODUCTION - The majority of land in Australia consists of freehold title. Registration of ownership of freehold title is recorded using the Torrens ...more
On November 21, 2023, the Government of Canada released its Fall Economic Statement (“2023 FES”) which includes certain sales and excise tax measures, including draft legislative proposals to implement long-awaited new...more
This dispute arose when the Canada Revenue Agency (“CRA”) reassessed President’s Choice Bank (“PCB”) for uncollected GST/HST on bundled supplies made to a major Canadian bank (the “Bank”) and denied the Bank’s rebate claims...more
In this final Part 10 of our build-to-rent (BTR) series, we identify some key investment structuring challenges for investors in new BTR assets in Australia, and consider how investors may be able to overcome some of them...more
Le 14 septembre 2023, le gouvernement fédéral a annoncé un allègement bienvenu qui touchera les propriétaires et les promoteurs d’immeubles d’habitation construits expressément pour la location, de logements pour étudiants et...more
As an incentive to builders to create more rental housing units, the federal government has announced the effective elimination of the goods and services tax (GST) payable on newly constructed rental housing, such as...more
On September 14, 2023, the federal government announced a welcome relief that will affect owners and developers of purpose-built rental buildings, student housing or seniors housing....more
On September 14, 2023, the Department of Finance Canada issued a news release (the “News Release”) regarding proposed legislation to be enacted in order to enhance the existing GST New Residential Rental Property (“NRRP”)...more
In July 2023, the Canada Revenue Agency (“CRA”) released GST/HST Notice 325 (the “Notice”) with respect to services provided by certain insurance intermediaries. The Notice essentially makes official the 180-degree turn the...more
Le 4 août 2023, le ministère des Finances (le « ministère ») a publié de multiples propositions législatives et notes explicatives connexes (les « propositions du 4 août »). Ces propositions du 4 août comprennent des...more
On August 4, 2023, the Department of Finance (Finance) released a significant package of draft legislative proposals and related explanatory notes (August 4 Proposals). The August 4 Proposals include updated legislative...more
The term “indirect tax” is used to describe taxes that are imposed on goods, land, or services (or transactions involving goods, land, or services). In contrast, “direct taxes” are imposed on income or profits. The most...more
On June 27, 2023, the Tax Court of Canada (“TCC”) dismissed the appeal of a Schedule II bank (the “Bank”) regarding its entitlement to input tax credits (“ITCs”) for GST/HST payable on expenses incurred in connection with the...more
On June 8, 2023, the Federal Court of Appeal upheld a Tax Court of Canada decision that, by allowing a supplier of Automated Teller Machines (“ATMs”) to place and operate ATMs throughout its casino resort, a casino operator...more
There is one common law rule that haunts most law students, and many legal practitioners: “no interest is good unless it must vest, if at all, not later than twenty-one years after some life in being at the creation of the...more
The April Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 5.0%. The April applicable federal rate (“AFR”) for use with a sale to a defective grantor trust or intra-family loan...more
On December 22, 2022, the Court of Appeal of Québec upheld a Superior Court ruling that GST and QST input tax credits and refunds (“ITCs/ITRs”) claimed by a petitioner in connection with damage payments arising from...more