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…

Tax Planning Bomb Shell

“Changes to strategies that have been the basis for shareholder remuneration planning for decades will be eliminated”…

Major changes to the Voluntary Disclosures Program

“relief from penalties will be significantly curtailed” The Voluntary Disclosures Program (VDP) is a CRA administrative program…

FATCA and Catch up Filing – Is the end in sight?

Since 2009, the U.S. Internal Revenue Service (“IRS”) has had a number of programs in place to…

Foreign Bank Account Reports – Make Sure to File Them

A United States person is required to file FinCEN Form 114, “Report of Foreign Bank and Financial…

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…

Canadian Tax Treatment of Certain Florida and Delaware Partnerships

the CRA views these entities to be corporations for Canadian income tax purposes. Residents of Canada who…

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…

Upstream Loans

taxpayers may need to act now  Prior to 2011, upstream loans were used to defer income offshore…

Section 119: Flawed Relief from Departure Tax

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

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