Taxation in Canada

Taxation in Canada is a shared responsibility between the federal government and the various provincial and territorial legislatures. Under the Constitution Act, 1867, taxation powers are vested in the Parliament of Canada under s. 91(3) for:

“

3. The raising of Money by any Mode or System of Taxation.

 ”

The provincial legislatures have a more restricted authority under ss. 92(2) and 92(9) for:

“

2. Direct Taxation within the Province in order to the raising of a Revenue for Provincial Purposes.

...

9. Shop, Saloon, Tavern, Auctioneer, and other Licences in order to the raising of a Revenue for Provincial, Local, or Municipal Purposes.

 ”

In turn, the provincial legislatures have authorized municipal councils to levy specific types of direct tax, such as property tax.

The powers of taxation are circumscribed by ss. 53 and 54 (both extended to the provinces by s. 90), and 125, which state:

“

53. Bills for appropriating any Part of the Public Revenue, or for imposing any Tax or Impost, shall originate in the House of Commons.

54. It shall not be lawful for the House of Commons to adopt or pass any Vote, Resolution, Address, or Bill for the Appropriation of any Part of the Public Revenue, or of any Tax or Impost, to any Purpose that has not been first recommended to that House by Message of the Governor General in the Session in which such Vote, Resolution, Address, or Bill is proposed.

...

125. No Lands or Property belonging to Canada or any Province shall be liable to Taxation.

 ”

Nature of the taxation power in Canada

Since the 1930 Supreme Court of Canada ruling in Lawson v. Interior Tree Fruit and Vegetables Committee of Direction, taxation is held to consist of the following characteristics:[1]

  • it is enforceable by law;
  • imposed under the authority of the legislature;
  • levied by a public body; and
  • intended for a public purpose.

In order for a tax to be validly imposed, it must meet the requirements of s. 53 of the Constitution Act, 1867, but the authority for such imposition may be delegated within certain limits. Major J noted in Re Eurig Estate:[2]

In my view, the rationale underlying s. 53 is somewhat broader. The provision codifies the principle of no taxation without representation, by requiring any bill that imposes a tax to originate with the legislature. My interpretation of s. 53 does not prohibit Parliament or the legislatures from vesting any control over the details and mechanism of taxation in statutory delegates such as the Lieutenant Governor in Council. Rather, it prohibits not only the Senate, but also any other body other than the directly elected legislature, from imposing a tax on its own accord.[3]

This was endorsed by Iacobucci J in Ontario English Catholic Teachers' Assn. v. Ontario (Attorney General), and he further stated:

The delegation of the imposition of a tax is constitutional if express and unambiguous language is used in making the delegation. The animating principle is that only the legislature can impose a new tax ab initio. But if the legislature expressly and clearly authorizes the imposition of a tax by a delegated body or individual, then the requirements of the principle of “no taxation without representation” will be met. In such a situation, the delegated authority is not being used to impose a completely new tax, but only to impose a tax that has been approved by the legislature. The democratic principle is thereby preserved in two ways. First, the legislation expressly delegating the imposition of a tax must be approved by the legislature. Second, the government enacting the delegating legislation remains ultimately accountable to the electorate at the next general election.[4]

Taxation vs regulatory charge

In Westbank First Nation v. British Columbia Hydro and Power Authority, the SCC declared that a government levy would be in pith and substance a tax if it was "unconnected to any form of a regulatory scheme."[5] The test for a regulatory fee set out in Westbank requires:

  • a complete, complex and detailed code of regulation;
  • a regulatory purpose which seeks to affect some behaviour;
  • the presence of actual or properly estimated costs of the regulation; and
  • a relationship between the person being regulated and the regulation, where the person being regulated either benefits from, or causes the need for, the regulation.[6]

In 620 Connaught Ltd. v. Canada (Attorney General), the Westbank framework was qualified to require "a relationship between the charge and the scheme itself."[7] This has resulted in situations where an imposition can be characterized as neither a valid regulatory charge nor a valid tax. In Confédération des syndicats nationaux v. Canada (Attorney General), a funding scheme for employment insurance that was intended to be self-financing instead generated significant surpluses that were not used to reduce EI premiums in accordance with the legislation. It was therefore held to be contrary to the federal unemployment insurance power under s. 91(2A) and thus not a valid regulatory charge, and there was no clear authority in certain years for setting such excess rates, so it was not a valid tax.[8]

Direct vs indirect taxation

The question of whether a tax is "direct taxation" (and thus falling within provincial jurisdiction) was summarized by the Judicial Committee of the Privy Council in The Attorney General for Quebec v Reed,[9] where Lord Selborne stated:

The question whether it is a direct or indirect tax cannot depend on those special events which may vary in particular cases; but the best general rule is to look to the time of payment; and if at the time the ultimate incidence is uncertain, then, as it appears to their Lordships, it cannot, in this view, be called direct taxation within the meaning of [s. 92(2)]...

"Indirect taxation" has been summarized by Rand J in Canadian Pacific Railway Co. v. Attorney General for Saskatchewan in these words:[10]

In Esquimalt,[11] Lord Greene ... speaks of the "fundamental difference" between the "economic tendency" of an owner to try to shift the incidence of a tax and the "passing on" of the tax regarded as the hallmark of an indirect tax. In relation to commodities in commerce, I take this to lie in the agreed conceptions of economists of charges which fall into the category of accumulating items: and the question is, what taxes, through intention and expectation, are to be included in those items? If the tax is related or relateable, directly or indirectly, to a unit of the commodity or its price, imposed when the commodity is in course of being manufactured or marketed, then the tax tends to cling as a burden to the unit or the transaction presented to the market. However much, in any case, these may be actually "intended" or "expected" to be passed on, it is now settled that they are to be so treated.

When the definition of "direct taxation" is read with s. 92(2)'s requirement that it be levied "within the Province", it has been held that:

  • provincial taxes must fasten onto provincially located persons, property or transactions,[12] or to extraprovincial persons conducting economic activity within the province[13]
  • they may not be levied on goods destined for export[14]
  • they must not impede the flow of interprovincial trade[14]

Licensing fees and regulatory charges

Allard Contractors Ltd. v. Coquitlam (District) held that:

  • provincial legislatures may charge a fee that is of an indirect nature, where it is supportable as ancillary or adhesive to a valid regulatory scheme under a provincial head of power.[15]
  • in obiter, La Forest J's observation was cited with approval that s. 92(9) (together with the provincial powers over property and civil rights and matters of a local or private nature) allows for the levying of license fees even if they constitute indirect taxation.[16]

Administration

Federal taxes are collected by the Canada Revenue Agency (CRA). Under tax collection agreements, the CRA collects and remits to the provinces:

  • provincial personal income taxes on behalf of all provinces except Quebec, through a system of unified tax returns.
  • corporate taxes on behalf of all provinces except Quebec and Alberta.
  • that portion of the Harmonized Sales Tax that is in excess of the federal Goods and Services Tax (GST) rate, with respect to the provinces that have implemented it.

The Agence du Revenu du Québec collects the GST in Quebec on behalf of the federal government, and remits it to Ottawa.

↓Creation of Departments[a 1]
↓Creation of Department of Customs and Inland Revenue[a 2]
↓Creation of Canada Customs and Revenue Agency[a 3]
↓Substitution of Commissioners for Ministers[a 4]
↓Restoration of Ministers[a 5]
↓Renaming to Department of Customs and Excise[a 6]
↓CCRA renamed as CRA[a 7]
↓Adoption of present name of department[a 8]
↓Transfer of border services to separate agency[a 7]
Department of Customs[a 9]
Department of Inland Revenue[a 10]
│
1867
│
1887
│
1907
│
1927
│
1947
│
1967
│
1987
│
2007
│
2027
│
2047

Timeline of Canadian federal tax administration

  1. ↑ Established by Order in Council on 1 July 1867, and given statutory basis in 1868.
  2. ↑ Order in Council of 18 May 1918, pursuant to the Public Service Rearrangement and Transfer of Duties Act.
  3. ↑ Canada Revenue Agency Act (S.C. 1999, c. 17)
  4. ↑ SC 50-51 Vict., c. 11
  5. ↑ SC 60-61 Vict., c. 18
  6. ↑ SC 11-12 Geo. V, c. 26
  7. 1 2 Canada Border Services Agency Act (S.C. 2005, c. 38)
  8. ↑ SC 17 Geo. V, c. 34
  9. ↑ SC 31 Vict., c. 43
  10. ↑ SC 31 Vict., c. 49

Income taxes

The Parliament of Canada entered the field with the passage of the Business Profits War Tax Act, 1916[17] (essentially a tax on larger businesses, chargeable on any accounting periods ending after 1914 and before 1918).[18] It was replaced in 1917 by the Income War Tax Act, 1917[19] (covering personal and corporate income earned from 1917 onwards).[20] Similar taxes were imposed by the provinces in the following years.[21]

Province Introduction of personal income tax Introduction of corporate income tax Tax collection assumed by federal government Personal tax collection resumed by province Corporate tax collection resumed by province Corporate tax collection resumed by federal government
British Columbia 18761901 1941[it 1]
Alberta 1932[it 2]1932[it 2] 1941[it 1] 1981
Saskatchewan 19321932 1941[it 1]
Manitoba 1923 1924 1938[it 3]
Ontario 1936[it 4]1932[it 5] 1936[it 6] 1947 2009[it 7]
Québec 19391932 1940[it 8] 1954 1947
New Brunswick 1941[it 1]
Nova Scotia 1941[it 1]
Prince Edward Island 18941894 1938[it 9]
Newfoundland and Labrador 1949
  1. 1 2 3 4 5 introduced under the Wartime Tax Rental Agreement
  2. 1 2 "The Income Tax Act, SA 1932, c. 5". Retrieved 2013-03-18.
  3. ↑ SM 1937, c. 43; SM 1937–38, c. 39
  4. ↑ SO 1936, c. 1
  5. ↑ SO 1932, c. 8
  6. ↑ SO 1936, c. 1, s. 76, subsequently authorized by Order in Council P.C. 1081 of May 14, 1937
  7. ↑ "Ontario transitional tax debits and credits". Canada Revenue Agency. Retrieved 2013-03-17.
  8. ↑ SQ 1940, c. 16
  9. ↑ SPEI 1937, c. 18; SPEI 1938, c. 10

Municipal income taxes existed as well in certain municipalities, but such taxation powers were gradually abolished as the provinces established their own collection régimes, and none survived the Second World War, as a consequence of the Wartime Tax Rental Agreements.

  • From 1850, municipal councils in Ontario possessed authority to levy taxes on income, where such amount was greater than the value of a taxpayer's personal property.[22] The personal property limitation was removed with the passage of the Assessment Act in 1904.[23] By 1936, some 200 councils ranging in size from Toronto to Blenheim Township were collecting such taxes.[24] Toronto levied personal income taxes until 1936, and corporate income taxes until 1944.[25]
  • From 1855 to 1870, and once more from 1939,[26] income tax was imposed on residents of Quebec City.[27] In 1935, a municipal income tax was imposed on the income of individuals resident or doing business in Montreal and the municipalities of the Montreal Metropolitan Commission.[28] Similar income taxes were also imposed in Sherbrooke from 1886 to 1912, in Sorel from 1889, and Hull from 1893.[27]
  • In Prince Edward Island, Summerside had an income tax from 1870 to 1880, and Charlottetown imposed one from 1880 to 1888.[29]
  • While Nova Scotia permitted municipal income tax in 1835, Halifax was the first municipality to levy one in 1849.[29]
  • New Brunswick allowed the collection of income taxes in 1831.[30] However, serious enforcement did not begin until 1849, but it was only in 1908 when all municipalities in the Province were required to collect it.[29]

Personal income taxes

Both the federal and provincial governments have imposed income taxes on individuals, and these are the most significant sources of revenue for those levels of government accounting for over 40% of tax revenue. The federal government charges the bulk of income taxes with the provinces charging a somewhat lower percentage, except in Quebec. Income taxes throughout Canada are progressive with the high income residents paying a higher percentage than the low income residents. Alberta has a flat-rate provincial income tax.[31]

Where income is earned in the form of a capital gain, only half of the gain is included in income for tax purposes; the other half is not taxed.

Settlements and legal damages are generally not taxable, even in circumstances where damages (other than unpaid wages) arise as a result of breach of contract in an employment relationship.[32]

Federal and provincial income tax rates are shown at Canada Revenue Agency's website.

Personal income tax can be deferred in a Registered Retirement Savings Plan (RRSP) (which may include mutual funds and other financial instruments) that are intended to help individuals save for their retirement. Tax-Free Savings Accounts allow people to hold financial instruments without taxation on the income earned.

Corporate taxes

Companies and corporations pay tax on profit income and on capital. These make up a relatively small portion of total tax revenue. Tax is paid on corporate income at the corporate level before it is distributed to individual shareholders as dividends. A tax credit is provided to individuals who receive dividend to reflect the tax paid at the corporate level. This credit does not eliminate double taxation of this income completely, however, resulting in a higher level of tax on dividend income than other types of income. (Where income is earned in the form of a capital gain, only half of the gain is included in income for tax purposes; the other half is not taxed.)

Corporations may deduct the cost of capital following capital cost allowance regulations. The Supreme Court of Canada has interpreted the Capital Cost Allowance in a fairly broad manner, allowing deductions on property which was owned for a very brief period of time,[33] and property which is leased back to the vendor from which it originated.[34]

Starting in 2002, several large companies converted into "income trusts" in order to reduce or eliminate their income tax payments, making the trust sector the fastest-growing in Canada as of 2005. Conversions were largely halted on October 31, 2006, when Finance Minister Jim Flaherty announced that new income trusts would be subject to a tax system similar to that of corporations, and that these rules would apply to existing income trusts after 2011.

See also: Income trust

Capital tax is a tax charged on a corporation's taxable capital. Taxable capital is the amount determined under Part 1.3 of the Income Tax Act (Canada) plus accumulated other comprehensive income.

On January 1, 2006, capital tax was eliminated at the federal level. Some provinces continued to charge corporate capital taxes, but effective July 1, 2012, provinces have stopped levying corporation capital taxes. In Ontario the corporate capital tax was eliminated July 1, 2010 for all corporations, although it was eliminated effective January 1, 2007, for Ontario corporations primarily engaged in manufacturing or resource activities. In British Columbia the corporate capital tax was eliminated as of April 1, 2010.

From 1932[35] until 1951,[36] Canadian companies were able to file consolidated tax returns, but this was repealed with the introduction of the business loss carryover rules.[37] In 2010, the Department of Finance launched consultations to investigate whether corporate taxation on a group basis should be reintroduced.[37] As no consensus was reached in such consultations, it was announced in the 2013 Budget that moving to a formal system of corporate group taxation was not a priority at this time.[38]

International taxation

Canadian residents and corporations pay income taxes based on their world-wide income. Canadians are in principle protected against double taxation receiving income from certain countries which gave agreements with Canada through the foreign tax credit, which allows taxpayers to deduct from their Canadian income tax otherwise payable from the income tax paid in other countries. A citizen who is currently not a resident of Canada may petition the CRA to change her or his status so that income from outside Canada is not taxed.

If you are a non-resident of Canada and you have taxable earnings in Canada (e.g. rental income and property disposition income) you will be required to pay Canadian income tax on these amounts. Rents paid to non-residents are subject to a 25% withholding tax on the “gross rents”, which is required to be withheld and remitted to Canada Revenue Agency (“CRA”) by the payer (i.e. the Canadian agent of the non-resident, or if there is no agent, the renter of the property) each time rental receipts are paid or credited to the account of the non-resident by the payer. If the payer does not remit the required withholding taxes by the 15th day following the month of payment to the non-resident, the payer will be subject to penalties and interest on the unpaid amounts.[39]

Payroll taxes

Employers are required to remit various types of payroll taxes to the different jurisdictions they operate in:

Jurisdiction Type
Federal
Ontario Employer Health Tax[40]
Quebec
All provinces Workers' compensation premiums

Consumption taxes

Sales taxes

The federal government levies a value-added tax of 5%, called the Goods and Services Tax (GST), and, in five provinces, the Harmonized Sales Tax (HST). The provinces of British Columbia, Saskatchewan and Manitoba levy a retail sales tax, and Quebec levies its own value-added tax, which is called the Quebec Sales Tax. The province of Alberta and the territories of Nunavut, Yukon and Northwest Territories do not levy sales taxes of their own.

Retail sales taxes were introduced in the various provinces on these dates:[47][21][48]

Evolution of sales tax régimes by jurisdiction
Province Introduction of RST Initial RST rate Last RST rate RST repealed Conversion to HST Conversion to QST Reversion to RST
British Columbia 1948 3% 7% 2010 2013
Alberta 1936[a 1] 2% 2% 1937[a 2]
Saskatchewan[a 3] 1937 2% 5%
Manitoba 1964[a 4] 5% 8%
Ontario[a 5] 19613% 8% 2010
Québec 1940[a 6]2% 9.5% 2012
New Brunswick 19504% 11% 1997
Nova Scotia 19593% 11% 1997
Prince Edward Island[a 7] 19604% 10% 2013
Newfoundland and Labrador 19503% 12% 1997
  1. ↑ "Ultimate Purchasers Tax Act, SA 1936, c. 7". Retrieved 2013-03-17.
  2. ↑ "An Act to amend the Ultimate Purchasers Tax Act, SA 1937 (2nd Session), c. 6". Retrieved 2013-03-17.
  3. ↑ "Taxation". Encyclopedia of Saskatchewan. Retrieved 2013-03-17.
  4. ↑ originally a Revenue Tax charged on a select list of supplies, replaced by a more general retail sales tax in 1967 - Ontario Committee on Taxation III. pp. 212–213.
  5. ↑ "Retail Sales Tax". Ministry of Finance (Ontario). Retrieved 2013-03-17.
  6. ↑ Quebec municipalities, beginning with Montreal in 1935 (SQ 1935, ch. 112), levied their own sales tax at the rate of 2%, which continued until 1964.
  7. ↑ "Revenue Tax Rate History". Department of Finance, Energy and Municipal Affairs (PEI). Retrieved 2013-03-17.

Current sales tax rates

Current sales tax rates by jurisdiction[b 1]
Province HST GST PST Total Tax
British Columbia 5% 7% 12%
Alberta 5% 5%
Saskatchewan 5% 5% 10%
Manitoba 5% 8% 13%
Ontario 13% 13%
Québec 5% 9.975%[b 2] 14.975%
New Brunswick 13% 13%
Nova Scotia 15% 15%
Prince Edward Island 14% 14%
Newfoundland and Labrador 13% 13%

Excise taxes

Both the federal and provincial governments impose excise taxes on inelastic goods such as cigarettes, gasoline, alcohol, and for vehicle air conditioners. A great bulk of the retail price of cigarettes and alcohol are excise taxes. The vehicle air conditioner tax is currently set at $100 per air conditioning unit. Canada has some of the highest rates of taxes on cigarettes and alcohol in the world. These are sometimes referred to as sin taxes. It is generally accepted that higher prices deter consumption of these items which have been deemed to increase health care costs stemming from those who use them.

Year for introduction of taxes on motor fuels[g 1]
Jurisdiction Fuel tax Carbon tax Local fuel tax
Federal 1975[g 2][g 3]
British Columbia 1923 2008[g 4]
1999 (Metro Vancouver)
2010 (Capital Regional District)
Alberta 1922
Saskatchewan 1928
Manitoba 1923
Ontario 1925[g 5]
Quebec 1924 2007[g 6]
1996 (Montreal Metropolitan Community)
New Brunswick 1926
Nova Scotia 1926
Prince Edward Island 1924
Newfoundland before Confederation
  1. ↑ Report of the Ontario Committee on Taxation III. 1967. p. 249.
  2. ↑ During 1941–1947, there had been a temporary excise tax in effect.
  3. ↑ "Partial Text of Tax and Tariff Proposals made in Ilsley Budget". Ottawa Citizen. 30 April 1941.
  4. ↑ Carbon Tax Act, SBC 2008, c. 40
  5. ↑ The Gasoline Tax Act, SO 1925, c. 28
  6. ↑ An Act respecting the implementation of the Québec Energy Strategy and amending various legislative provisions, 2006, c. 46

At the federal level, Canada has imposed other excise taxes in the past:

  • From 1915 to 1953, on the issue of cheques and other commercial paper.[49]
  • From 1920 to 1927, on advances of money[50]
  • From 1920 to 1953, on the transfer of securities.[51] Initially applying to shares,[52] it was extended to cover bonds and related items in 1922.[53]
  • From 1923 to 1926, on the issue of receipts.[54]

Wealth taxes

Property taxes

The municipal level of government is funded largely by property taxes on residential, industrial and commercial properties. These account for about ten percent of total taxation in Canada. There are two types. The first is an annual tax levied on the value of the property (land plus buildings). The second is a land transfer tax levied on the sale price of properties everywhere except Alberta, Saskatchewan and rural Nova Scotia.

Estate tax

Estate taxes have been held to be valid "direct taxation within the province,"[55] but they cannot be charged where property is left outside the province to beneficiaries who are neither resident nor domiciled in the province.[56][57] Succession duties were in effect in the various provinces at the following times:[58]

Province Introduced Repealed
Ontario 1892 1979
Quebec 1892 1986
New Brunswick 1892 1974
Nova Scotia 1892 1974
Manitoba 1893 1977
Prince Edward Island 1894 1971
British Columbia 1894 1977
Saskatchewan 1905 1977
Alberta 1905 1947
Newfoundland before Confederation 1974

Death taxes, which were not subject to the territorial limitations that affected provincial taxation, were first introduced at the federal level under the Dominion Succession Duty Act in 1941,[59] which was later replaced by the Estate Tax Act in 1958.[60] The latter was repealed at the end of 1971. From 1947 to 1971, there was a complicated set of federal-provincial revenue-sharing arrangements, where:[58]

  • In Newfoundland, Prince Edward Island, Nova Scotia, New Brunswick and Manitoba, the federal government collected estate taxes at full rates, but remitted 75% of the revenues derived from each of those provinces;
  • In Alberta and Saskatchewan, the federal government collected estate taxes at full rates, but remitted 75% of the revenues derived from each of those provinces, which was rebated back to the estate;
  • In British Columbia, the federal government collected estate taxes at only 25% of the full rate, and the province continued to levy its own succession duty;
  • In Ontario and Quebec, the federal government collected estate taxes at only 50% of the full rate, and remitted 50% of such collections to such provinces, and the provinces continued to levy their own succession duties.

Upon the repeal of the federal estate tax in 1972, the income tax régime was altered to incorporate consequences arising from the death of a taxpayer, which may result in tax being owed:

  • the property of an estate is said to have incurred a "deemed disposition" at fair market value, thus triggering liability for capital gains and other inclusions into income[61]
  • certain deductions and deferrals are available with respect to capital gains[62]
  • several options are available for applying any outstanding net capital losses[63]
  • income earned or accrued up to the date of death is taxed on the final tax return of the deceased at normal tax rates, but there are several additional optional tax returns that may be filed as well for certain types of income[64]
  • income earned after the date of death is to be declared on a separate return filed by the trust for the estate[65]
  • beneficiaries are taxed on amounts paid from Registered Retirement Savings Plans and Registered Retirement Income Funds, but certain rollover reliefs are available[66]

See also

Further reading

References

  1. ↑ Lawson v. Interior Tree Fruit and Vegetables Committee of Direction 1930 CanLII 2, {1931} SCR 357 (16 February 1930)
  2. ↑ Paul LeBreux (1999). "Eurig Estate: Another Day, Another Tax" (PDF). Canadian Tax Journal (Canadian Tax Foundation) 47 (5): 1126–1163. Retrieved 12 April 2013.
  3. ↑ Re Eurig Estate 1998 CanLII 801 at par. 30, [1998] 2 SCR 565 (22 October 1998)
  4. ↑ Ontario English Catholic Teachers' Assn. v. Ontario (Attorney General) 2001 SCC 15 at par. 74, [2001] 1 SCR 470 (8 March 2001)
  5. ↑ Westbank First Nation v. British Columbia Hydro and Power Authority 1999 CanLII 655 at par. 43, [1999] 3 SCR 134 (10 September 1999)
  6. ↑ Westbank First Nation, par. 44
  7. ↑ 620 Connaught Ltd. v. Canada (Attorney General) 2008 SCC 7 at par. 27, [2008] 1 SCR 131 (29 February 2008)
  8. ↑ Confédération des syndicats nationaux v. Canada (Attorney General) 2008 SCC 68, [2008] 3 SCR 511 (11 December 2008)
  9. ↑ The Attorney General for Quebec v Reed [1884] UKPC 44, [1883] 10 AC 141 (26 November 1884), P.C. (on appeal from Canada)
  10. ↑ Canadian Pacific Railway Co. v. Attorney General for Saskatchewan 1952 CanLII 39 at pp. 251–252, [1952] 2 SCR 231 (30 June 1952)
  11. ↑ Attorney-General for British Columbia v. Esquimalt and Nanaimo Railway Company and others [1949] UKPC 48, [1950] AC 87 (2 November 1949), P.C. (on appeal from Canada)
  12. ↑ Magnet 1978, p. 500.
  13. ↑ Magnet 1978, pp. 500–501.
  14. 1 2 Magnet 1978, p. 506.
  15. ↑ Allard Contractors Ltd. v. Coquitlam (District) 1993 CanLII 45, [1993] 4 SCR 371 (18 November 1993)
  16. ↑ G.V. La Forest (1981). The Allocation of Taxing Power Under the Canadian Constitution (2nd ed.). Toronto: Canadian Tax Foundation. p. 159. ISBN 0-88808006-9.
  17. ↑ S.C. 1916, c. 11
  18. ↑ Breadner, R.W. (1919). "THE CANADIAN BUSINESS PROFITS AND INCOME WAR TAX ACTS: I. The Business Profits War Tax Act". The Bulletin of the National Tax Association (National Tax Association) 4 (4): 93–97. JSTOR 41785272.
  19. ↑ SC 1917, Chap. 28
  20. ↑ Pontifex, Brian (1917). The Income War Tax Act, 1917, with explanations by the Minister of Finance and Instructions from the Finance Department. Toronto: Carswell.
  21. 1 2 Selected aspects of the power to tax in the Canadian federation, 1876–1997. Retrieved 2013-03-17.
  22. ↑ An Act to establish a more equal and just system of Assessment in the several Townships, Villages, Towns and Cities in Upper Canada, S.Prov.C. 1850, c. 67, s. 4
  23. ↑ The Assessment Act, S.O. 1904, c. 23, s. 5
  24. ↑ Robert B. Bryce (1986). Maturing in Hard Times: Canada's Department of Finance Through the Great Depression. Institute of Public Administration of Canada. p. 267. ISBN 0-7735-0555-5.
  25. ↑ John Sewell (April 2011). "Letter". The Walrus. Retrieved 2013-03-18.
  26. ↑ SQ 1939, ch. 102
  27. 1 2 Gillespie 1995, p. 263.
  28. ↑ "Public Notice: City of Montreal Bylaw No. 1337 - By-Law to impose an Income Tax in the Territory of the City of Montreal and of Certain Municipalities under the control of the Montreal Metropolitan Commission". Montreal Gazette. 30 April 1935. Retrieved 22 March 2013., by virtue of SQ 1934, ch. 112
  29. 1 2 3 Gillespie 1995, p. 262.
  30. ↑ Johnson, J.A. (1974). "Methods of Curbing Local Government Financial Problems: Implications for Urban Government in Canada". In Dickerson, M.O.; Drabek, S.; Woods, J.T. Problems of Change in Urban Government. Waterloo: Wilfrid Laurier University Press. p. 162. ISBN 0-88920-089-0.
  31. ↑ Canada Revenue Agency
  32. ↑ "Schwartz v. Canada, [1996] 1 S.C.R. 254".
  33. ↑ "Hickman Motors Ltd. v. Canada, [1997] 2 S.C.R. 336".
  34. ↑ "Canada Trustco Mortgage Co. v. Canada, [2005] 2 S.C.R. 601".
  35. ↑ SC 1932-33, c. 41, section 13, subsequently replaced by SC 1948, c. 52, section 75
  36. ↑ SC 1951, c. 51, section 26
  37. 1 2 Maureen Donnelly; Allister W. Young (2011). "Group Relief for Canadian Corporate Taxpayers–At Last?". Canadian Tax Journal (Canadian Tax Foundation) 59 (2): 239–263. Retrieved 16 March 2013.
  38. ↑ "Budget Briefing 2013". Osler, Hoskin & Harcourt. 21 March 2013. Retrieved 8 April 2013.
  39. ↑ http://matthewgustavson.ca/blog/nonresident.html
  40. ↑ "Employer Health Tax".
  41. ↑ "Contributions to the Québec Pension Plan (QPP)".
  42. ↑ "Contribution to the Health Services Fund".
  43. ↑ "Québec Parental Insurance Plan (QPIP) Premiums".
  44. ↑ "Contribution to the Financing of the Commission des normes du travail".
  45. ↑ "Contribution to the Workforce Skills Development and Recognition Fund".
  46. ↑ "Compensation Tax for a Financial Institution That Is Not a Corporation".
  47. ↑ Satya Poddar; Morley English (1995). "Fifty Years of Canadian Commodity Taxation: Key Events and Lessons for the Future" (PDF). Canadian Tax Journal (Canadian Tax Foundation) 43 (5): 1096–1119. Retrieved 17 March 2013.
  48. ↑ Albert John Robinson. Public Finance in Canada: Selected Readings. p. 262. Retrieved 17 March 2013.
  49. ↑ Christopher D. Ryan. "Canada's Excise Tax on Cheques and other Types of Commercial Paper, 1915-1953" (PDF).
  50. ↑ Christopher D. Ryan. "Canada's Excise Tax on Advances of Money, 1920-1927" (PDF).
  51. ↑ Christopher D. Ryan. "Canada's Excise Tax on Transfers of Stocks and Bonds, 1920-1953" (PDF).
  52. ↑ SC 1920, c. 71
  53. ↑ SC 1922, c. 47
  54. ↑ Christopher D. Ryan. "Canada's Excise Tax on Receipts, 1923-1926" (PDF).
  55. ↑ Attorney General of British Columbia v. Canada Trust Co. et al. 1980 CanLII 221, [1980] 2 SCR 466 (27 June 1980), Canada)
  56. ↑ Charles S. Cotton and another v The King [1913] UKPC 56, [1914] AC 176; (1913), 15 DLR 283 (PC) (11 November 1913), P.C. (on appeal from Canada)
  57. ↑ The Provincial Treasurer of Alberta and another v Clara E. Kerr and another [1933] UKPC 57, [1933] AC 710; [1933] 4 DLR 81 (PC) (27 July 1933), P.C. (on appeal from Alberta)
  58. 1 2 Wolfe D. Goodman (1995). "Death Taxes in Canada, in the Past and in the Possible Future" (PDF). Canadian Tax Journal (Canadian Tax Foundation) 43 (5): 1360–1376. Retrieved 16 March 2013.
  59. ↑ SC 1940-41, c. 14
  60. ↑ SC 1958, c. 29
  61. ↑ "Deemed disposition of property".
  62. ↑ "T4037 - Capital Gains".
  63. ↑ "Net capital losses".
  64. ↑ "Returns for the year of death".
  65. ↑ "Income reported on the T3 Trust Income Tax and Information Return".
  66. ↑ "Amounts paid from an RRSP or RRIF upon the death of an annuitant".

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