Canadian Lawyer

March 2021

The most widely read magazine for Canadian lawyers

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TAX LAWYERS AND ADVISORS 155 University Avenue, Suite 300, Toronto, Ontario, M5H 3B7 Tel.: (416) 847-7300 | PROUDLY RANKED ONE OF CANADA'S TOP 10 TAX LAW BOUTIQUES SINCE 2017 • Corporate & Business Taxation • Taxpayer Representation & Litigation • Canada/U.S. Cross-border Tax, Trust & Estate Planning 19 In late 2020, Canadian Lawyer asked lawyers, in-house counsel and clients from across Canada to vote on the top tax boutiques. They were asked to rank their top firms from a preliminary list, with a chance to nominate a firm that was not included. To qualify for our list and be voted for in our survey, firms were required to derive a minimum of 80 per cent of their work from tax law. HOW WE DID IT of the pandemic," says Felesky's Strawson. Moody agrees, saying that COVID-19 has exacerbated this issue but that many govern- ments — including Canada — were spending more than their revenues even prior to COVID, thus putting pressure to increase taxation directly or indirectly. "There are many possibilities for increased taxation and we are watching this closely." Vitaly Timokhov, a partner at TaxChambers LLP, says the federal government moved quickly to establish support programs through legislation such as Bill C-14, the COVID-19 Emergency Response Act. But the Canada Revenue Agency has sent strong signals that some of the benefits handed out during 2020 will likely be audited, even though it gave unclear communication on whether support would be given based on gross or net income. As well, there is concern that the govern- ment has not yet communicated how it will pay for all the COVID-19 programs. "Will it be increase in the capital gain inclusion? A possible increase in GST rates? Or limitations on the principal residence exemption?" Timokhov adds, "Given the size of the revenue that needs to be raised, it cannot be done through small incremental changes." Sheena Bassani of Barsalou Lawson Rheault Barristers & Solicitors says that one side effect of the pandemic was to further "digitize" the economy, leaving more profits outside the reach of tax administrators. While there have been attempts by the OECD to come up with a multinational solu- tion, Bassani says, "some countries, including Canada, are losing patience and, after launching digital sales taxes, have warned they will deploy their own approach to tax the income of digital giants."

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