The MLI: Getting Closer

On June 21, 2019, royal assent was given to Bill C-82 (An Act To Implement a Multilateral…

Post Mortem Pipeline Fails For Non-Resident Beneficiaries

On the death of the owner of a private company, taxes are payable on the deemed disposition…

Safe Income May Vary Within Shares of the Same Class

The anti-surplus-stripping provision in subsection 55(2), which can recharacterize a dividend as a capital gain, is not of…

Investing with a Foreign Broker and Buying Canadian Shares

Foreign brokers can attract Canadian investors, perhaps because of low management fees. The foreign broker may purchase…

Withholding Tax on Capital Distributions to Non-Residents

It is generally understood that income distributions by trusts to non-resident beneficiaries are subject to part XIII withholding…

Taxation of Canadian residential real estate: what non-residents need to know

This article provides a quick summary of important points concerning the taxation of Canadian residential real estate…

MNR v. KPMG: Professional Duty Overruled

In Canada (National Revenue) v. KPMG LLP (2016 FC 1322), KPMG sought unsuccessfully to quash an order to disclose…

Multi-Level Farming Structures and the Capital Gains Exemption

Taxpayers selling a farming (or fishing) business will want to have the assets that are being sold…

Section 119: Flawed Relief from Departure Tax

Section 119 is designed to provide relief from double taxation when an individual emigrates from Canada. Absent…

Doing Business In Canada

This chapter is a general overview of Canadian tax principles and has been prepared by Cadesky and…

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