Author: Sabrina Jackson-Nazareth

About Sabrina Jackson-Nazareth

Sabrina completed her JD/MBA degree at Osgoode Hall Law School and the Schulich School of Business with a specialization in Finance and as a member of the Dean’s Honour List. She earned her Bachelor of Science from the University of Toronto in Economics, where she graduated with High Distinction and as a Dean’s List Scholar. At Osgoode, Sabrina served as a Dean’s Fellow, sat on the Standing Committee for Teaching and Learning, and was an Associate Editor on the Osgoode Hall Law Journal.

Cross-border (Canada/US)

The 2023 Fall Economic Statement

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On November 21, 2023, Chrystia Freeland, the Deputy Prime Minister and the Federal Minister of Finance, unveiled the 2023 Fall Economic Statement (the “Economic Statement”). While the primary emphasis of the economic statement appears to be the Federal Government’s housing action plan and addressing issues of inflation and affordability, it also proposed technical updates on various tax-related matters. This article summarizes the proposed tax measures in the Economic Statement including updated implementation dates to previously announced measures.

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Analysis, Canada, Cross-border (Canada/US)

Revised proposals to amend the general anti-avoidance rule

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On August 4th, 2023, the Department of Finance Canada (“Finance”) released draft legislative proposals which included revised proposals to amend the general anti-avoidance rule (the “GAAR”) in section 245 of the Income Tax Act (Canada) (the “ITA”) (the “Revised GAAR Proposals”). The revised proposals follow several GAAR proposed amendments initially introduced in the 2023 Federal Budget (“Budget 2023”) tabled on March 28th, 2023.

The proposals to amend the GAAR will apply to transactions that occur on or after January 1st, 2024, except for the amendments to the preamble to the GAAR and related provisions which will come into force on Royal Assent.

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Analysis, Canada

Determining The Province Of Employment For Employees In Remote Work Arrangements

The Canada Revenue Agency (“CRA”) is introducing a new administrative policy (the “Policy”) relevant to remote workers to be effective on January 1, 2024. The policy will provide more certainty with respect to the province of employment of employees that are in a remote work arrangement in another province and are “attached” to an establishment of the employer.

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