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Andrew Morreale

Andrew Morreale is an associate in Baker McKenzie's Tax Practice Group in Toronto. Prior to joining the Firm, Andrew clerked for the judges of the Tax Court of Canada, was a corporate tax instructor at the University of Windsor, Faculty of Law and practiced in the international tax services group at a major accounting firm.

The Department of Finance released draft legislation on 3 November 2022 introducing new reporting obligations applicable to certain digital platform operators. These rules are intended to implement the OECD’s Model Rules for Reporting by Platform Operators with respect to Sellers in the Sharing and Gig Economy originally released in July 2020. These new Canadian measures are proposed to come into force on 1 January 2024.

On 4 February 2022, the Canadian Department of Finance released a proposed set of rules “EIFEL Rules”) intended to address concerns that Canadian taxpayers that are part of a multinational group are deducting excessive interest and other financing costs. The EIFEL Rules restrict the deductibility of net interest and other financing expenses. Although technical amendments are expected, it is anticipated that the EIFEL Rules will begin to apply for tax years that begin in 2023. Multinational groups with Canadian members are encouraged to consider the impact of the EIFEL Rules, and potential mitigation and optimization strategies, now.

The COVID-19 outbreak has led many countries to implement border controls as a temporary measure to curb infections, and many employers find their employees working from home or in locations outside the jurisdictions where employers typically operate or are located. International travel restrictions affect Boards of Directors and employees of…

The Canadian federal, provincial and municipal governments and courts have announced measures to provide relief to taxpayers in light of the impact of the restrictions aimed at slowing the spread of COVID-19. These measures are subject to change as the situation progresses. Tax Measures Tax filing and payment deadlines1 The…