Category: Tax Page 1 of 2

Unpaid Oil and Gas Municipal Property Taxes: Another Problem for the AER’s Closure and Liability Management System

On March 16, 2026, the government of Alberta announced a new report on the ongoing problem of unpaid municipal property taxes by a segment of the Alberta oil and gas industry. The announcement says the report is “the result of the Property Tax Accountability Strategy (PTAS) working group, which comprised Alberta’s government, the Rural Municipalities of Alberta (RMA), and rural municipal administrators, with support from representatives of the Alberta Energy Regulator (AER) and the oil and gas industry as observers.” The PTAS Report includes a description of the problem, along with 17 recommendations to address the problem. This post reviews some highlights of the PTAS Report’s description of the problem and comments on the likely effectiveness of the PTAS Report’s recommendations.

A Mugging on Bay Street

By Bryce Tingle

On October 17, 2025

In Corporate / Commercial, Securities, Tax

By: Bryce C. Tingle KC

Case Commented On: The RRSP Trust of James T. Grenon by its Trustee CIBC Trust Corporation v. Her Majesty the Queen, 2025 FCA 129 (CanLII)

PDF Version: A Mugging on Bay Street

Most corporate lawyers avoid reading tax court decisions. Tax is a pretty specialized practice area, and for non-specialists the entire area of tax law gives off the insalubrious air of a dark alley in an unfamiliar city. Except worse, because in a tax case you know for a fact there is someone down that alley who wants to rob you of your money.

Corporate lawyers should make an exception, however, for the recent decision in The RRSP Trust of James T. Grenon by its Trustee CIBC Trust Corporation v. Her Majesty the Queen (Grenon) by the Federal Court of Appeal. This is because the court finds itself interpreting provincial securities laws in a way that would be very surprising to most non-tax lawyers. In fact, the way the court (i) interprets the term “principal” (found in many private placement exemptions), (ii) the consequences that it suggests follow from imprecise investor representations in subscription agreements, and (iii) the way the court determines what constitutes a “lawful” offering under RRSP rules, all violate long-established securities practice and threaten to destabilize private placements of all kinds.

A Questionable Equity: Rectification and Tax Avoidance

By Drew Yewchuk

On December 18, 2017

In Contracts, Tax

By: Drew Yewchuk

PDF Version: A Questionable Equity: Rectification and Tax Avoidance

Case Commented On: Harvest Operations Corp. v Attorney General of Canada, 2017 ABCA 393 (CanLII)

Harvest Operations Corp. v Attorney General of Canada (Harvest Operations Corp. CA) is a case about an elaborate but unsuccessful tax avoidance maneuver and an attempt to get contract rectification. The details of the attempted tax avoidance are unreasonably complicated, and so I will focus on the facts necessary for the rectification issue (if you want to learn how to correctly perform the “bump transaction” method of avoiding capital gains tax, this post will not help you).

How the Canada Child Benefit Affects Separated Parents: The Post-relationship Breakdown Family Unit of Taxation

By Kyle Gardiner

On November 1, 2017

In Family, Tax

By: Kyle Gardiner

PDF Version: How the Canada Child Benefit Affects Separated Parents: The Post-relationship Breakdown Family Unit of Taxation

Matter Commented On: The Liberal Government’s Fall Economic Update, Indexing Canada Child Benefit Payments to Inflation

In its fall economic update last Tuesday, the Liberals announced that beginning in July 2018, Canada Child Benefit (CCB) payments will be increased amidst a smaller-than-expected deficit (of $18.4 billion this year, down from the spring projection of $25.5 billion), and a generally favourable economic outlook. This increase of $5.6 billion over five years is significant because it addresses what was the primary criticism of the CCB when it first came into place – that the benefit amounts were not indexed to inflation. The Liberals previously committed to indexing the amount to inflation if they were re-elected in 2019, and this upward adjustment represents a realization of that promise.

Charter Equality Challenges to the Income Tax Act: The Unsuccessful Streak is Strong, 30 Years On

By Kyle Gardiner

On September 2, 2016

In Constitutional, Tax

By: Kyle Gardiner

PDF Version: Charter Equality Challenges to the Income Tax Act: The Unsuccessful Streak is Strong, 30 Years On

Research Commented On: Shea Nerland Law LLP Fellowship Project on Tax Law and Equality, Summer 2016

On 2 May, 2016, I began a research project with Jonnette Watson Hamilton, Jennifer Koshan and Saul Templeton examining the role section 15 of the Charter plays in tax law. Over 50 variables were recorded from each of the 134 equality challenges to tax law that we analyzed. To read my post on one of these cases, Grenon v. Canada, 2016 FCA 4 (CanLII), see here. The data promises to be a rich tool for examining equality in the realm of tax law.

When I was conducting a literature review for this project, I reviewed Kathleen Lahey’s “The Impact of the Canadian Charter of Rights and Freedoms on Income Tax Law and Policy” in David Schneiderman & Kate Sutherland, eds, Charting the Consequences: The Impact of Charter Rights on Canadian Law and Politics (Toronto: University of Toronto Press, 1997) 109. In that study, Lahey conducted a review of 300 cases in which Charter challenges were brought to various income tax provisions between 1985 and 1995. The current research extends Lahey’s study, systematically reviewing section 15(1) Charter challenges to tax law that have been brought since the conclusion of her study in October, 1995. While many taxation provisions outside of the Income Tax Act, RSC 1985, c 1 (5^th Supp) have seen their share of section 15(1) challenges, the cases examined in our study were specifically section 15(1) equality challenges to a section or sections of the Income Tax Act. Our data awaits further statistical analysis beyond what has been done preliminarily here.