Tax & Trade Blog

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AMENDMENTS TO INDIRECT TAX RULES INCOMING

BILL C-31 NOW BEFORE FINANCE STANDING COMMITTEE & NEAR ENACTMENT

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As a follow up to our previous report on Canada’s Budget 2025 (the “Budget”), certain indirect tax measures proposed in the Budget are now being considered by Parliament, as the Budget 2025 Implementation Act, No. 2 (“Bill C-31”) received its second reading on June 3, 2026, and is currently at the House of Commons Standing Committee on Finance for consideration.

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CRA REFUNDS: WHERE DID MY MONEY GO?

CRA EXPLAINS WHY TAX CREDITS ARE AUTOMATICALLY TRANSFERRED

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Many taxpayers expect that once the Canada Revenue Agency (“CRA”) determines that they are entitled to a GST/HST or income tax refund, that the refund will simply be paid. Unfortunately, that is often not the case (!) with the CRA explaining its “set-off” rights in a recent industry roundtable, confirming that where refunds are due, those amounts can often be automatically transferred to satisfy outstanding balances in other CRA tax accounts.

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CRA AUDIT SETTLEMENTS: IS THAT A REAL THING?

CRA EXPLAINS HOW AUDITS CAN BE SETTLED & WHO REALLY MAKES THE DECISION

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Many taxpayers assume that once a CRA auditor starts an Audit, the Audit needs to be completed, with no opportunity to reach an early settlement on contentious issues. To the contrary, CRA has recently confirmed that many Audits can, in fact, be settled – albeit only after being subject to additional internal review before becoming final.

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BC HEADING BACK TOWARDS HARMONIZATION?

EXPANSION OF BC’S PROVINCIAL SALES TAX NARROWS THE GAP WITH THE HST

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As we previously blogged on here, British Columbia (“BC”) recently announced a further expansion of its Provincial Sales Tax (“PST”) base to certain goods and services including new professional services like accounting, architectural, and real estate services.

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DANGERS OF SELF-ISSUED USMCA CERTIFICATES

IMPORTERS MAY SIGN OWN CERTIFICATES – BUT AT OWN PERIL!

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One of the significant changes introduced by the Canada-United States-Mexico Agreement ("USMCA"), relative to the former NAFTA regime, was the expansion of who may complete and execute a USMCA Certification of Origin. In particular, importers are now permitted to complete and sign their own Certifications of Origin, rather than relying solely on exporters or producers.

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CRA BUSINESS ACCOUNT: AUTHORIZATION TRAPS

WHO CAN ACCESS WHAT?

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Most Canadian businesses assume that once an employee or professional advisor has been authorized to deal with the Canada Revenue Agency (“CRA”), that individual has the immediate ability to access and update all of the business’s online CRA information. As the CRA recently confirmed at an industry roundtable, that assumption is incorrect, with different authorization levels permitting different activities and access to one CRA Account not necessarily providing access to others.

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NEW OPPORTUNITIES FOR CANADA–UK TRADE

CANADA RATIFIES THE ACCESSION OF THE UK TO THE CPTPP

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On July 3, 2026, Canada ratified the Protocol on the Accession of the United Kingdom (“UK”) to the Comprehensive and Progressive Agreement for Trans-Pacific Partnership (“CPTPP”). The CPTPP will apply to Canada-UK trade effective September 1, 2026.

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WINERY COMPLIANCE IN ONTARIO AND B.C.

UNDERSTANDING THE FEDERAL EXCISE ACT 2001 COMPLIANCE REGIME

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Ontario and British Columbia (“B.C.”) are leading wine-producing provinces with well-established statutory frameworks governing how wineries may produce, market, and sell wine. Those provincial rules, however, are only part of the compliance picture. Wineries in Ontario and B.C. are also subject to the Federal Excise Act, 2001 (“EA 2001”), which imposes a separate compliance regime for licensing, reporting, removals, and recordkeeping.

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CRA ADOPTS 2-YEAR AUDIT WORKPLANS

LARGE BUSINESSES UNDER AUDIT TO FACE BROADER INITIAL RECORDS REQUESTS

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The Canada Revenue Agency (“CRA”) has recently announced an important administrative change affecting many large business audits (“Audits”). More specifically, CRA has advised at a major industry roundtable that rather than examining one taxation year at a time, Auditors may now adopt a two-year Audit workplan and request records from multiple years at the outset of an Audit.

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25% SURTAX ON WOOD CABINETS & VANITIES

200-DAY PROVISIONAL SURTAX PLACED ON CABINETRY – BUT COULD BE MADE PERMANENT

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On July 31, 2026, Canada enacted a provisional 25% safeguard surtax (“Safeguard Surtax”) on specific wood cabinet and vanity products.

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加拿大对中国纸杯和饭盒进行反倾销调查

反倾销调查或导致对中国相关产品加征额外关税

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CBSA Investigating Paperboard Cups and Containers

Anti-Dumping Investigations Could Impose Additional Duties on Chinese Goods

For the English Version of this Report, please click here.

2026年8月17日，加拿大边境服务署（CBSA）根据《特别进口措施法》(SIMA) 发布立案通知，就从中国进口的纸杯和饭盒涉嫌倾销及补贴展开调查。本次调查源于Great Pacific Enterprises Limited Partnership提交的一项投诉。

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CBSA INVESTIGATING PAPERBOARD CUPS AND CONTAINERS

ANTI-DUMPING INVESTIGATION COULD IMPOSE ADDITIONAL DUTIES ON CHINESE GOODS

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On August 17, 2026, the Canada Border Services Agency (“CBSA”) issued a Notice of Initiation of Investigation under the Special Import Measures Act (“SIMA”) in respect of the alleged dumping and subsidizing of paperboard cups and containers from China. This investigation was prompted by a complaint filed by Great pacific Enterprises Limited Partnership.

 

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HEALTH CANADA & MEDICAL DEVICE CLASS

HEALTH CLAIMS MAY CAUSE CHANGE IN MEDICAL DEVICE CLASSIFICATION!

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Canada has a robust system or regulations related to the importation, distribution and sale of regulated products in Canada. One highly regulated set of products is various Health Products regulated under the Canadian Food and Drugs Act (the “FDA”).

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CANADIAN SANCTIONS: DIFFICULT TO AVOID!

RECENT FCA DECISION DEMONSTRATES DIFFICULTIES FACING THOSE SEEKING RELIEF

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Canada maintains a broad and expanding sanctions regime, including measures targeting individuals connected to designated countries and restricted transactions which we have previously written about here. Once listed under Canadian sanctions, available remedies are limited. The primary resource is typically an application for judicial review before the Federal Court of Canada.

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CHAT GPT, HAVE I COMMITTED CUSTOMS FRAUD?

UPTICK IN FRADULENT UNDER-VALUATION WITH NEW TARIFF ENVIRONMENT

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Not since the 1980s and ‘90s has our specialized Customs, Trade & Indirect Tax Firm seen such an uptick in clients with significant under-valuation issues with the Canada Border Services Agency (“CBSA”).

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HEALTH CANADA & MEDICAL DEVICE CLASS

HEALTH CLAIMS MAY CAUSE CHANGE IN MEDICAL DEVICE CLASSIFICATION!

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As an International Trade Firm, a good part of our international trade practice is focused on product regulatory issues related to the importation, distribution and sale of regulated products in Canada. One highly regulated set of products is various Health Products regulated under the Canadian Food and Drugs Act (the “FDA”).

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COST AWARDS IN TAX LITIGATION

PROSPECTIVE TAX COURT LITIGANTS MUST UNDERSTAND COST RISKS

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"Costs" are awarded to successful litigants in tax litigation, as in most forms of litigation, but are not well understood by the public. Indeed, many litigants may head to the Tax Court of Canada (“TCC”) without first understanding the rules behind cost awards and without contemplating how these "costs" awards work when on the losing end of the litigation and/or appreciating that they may well be on the hook for the government’s legal bills when they do lose.

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NOT ALL DESIGN COSTS COUNT FOR DUTIES!

IMPORTER “WIN” AS CITT EXCLUDES CERTAIN DESIGN COSTS FROM VALUE FOR DUTY

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For businesses importing goods into Canada, the transaction value method (“TVM”) is the most commonly applicable method for determining the value for duty (“VFD”) under the Customs Act. However, for Canadian subsidiaries of foreign businesses, disputes often arise with the Canada Border Services Agency (“CBSA”) over VFD-related issues such as (1) the relevant “sale for export”, (2) purchaser in Canada status, and (3) inclusion of various design costs.

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ANTI-DUMPING – WHO IS THE EXPORTER?

CITT DECISION PROVIDES CLARIFICATION IN TRANSACTIONS WITH INTERMEDIARIES

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Anti-dumping duties (“ADD”) under the Special Import Measures Act (“SIMA”) generally apply where the normal value of targeted imported goods exceeds their export price. However, determining what ADDs are payable on particular goods may first require identifying who the “exporter” of the goods actually is in the circumstances since that will affect the normal value/export price.

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LATE TAX OBJECTIONS FACE STRICT DEADLINES

NO SECOND CHANCES WHEN APPLYING FOR AN EXTENSION OF TIME TO OBJECT

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A Notice of Objection (“NoO”) may be filed late – but ONLY if certain conditions and deadlines are met. Many taxpayers are unaware of the ability to apply for a late filing, and equally unaware that when THOSE deadlines are missed, it is all over!