When a Hotel Is Not a Lodge – 18(l)

“The CRA lost their argument that country hotels are lodges.” A recent case looked at whether payments…

Analysis of “Arm’s Length”

“CRA lost in its approach that any transactions that reduce taxes must be between non-arm’s length taxpayers.”…

Residency Test – Allchin Revisited

“Tax Court forced to take a second look at this case.” The Federal Court of Appeal concluded…

Alberta Unlimited Liability Company (“ABULC”)

“ABULC’s are cost-effective alternatives to NSULC’s.” Until May 2005, US investors in Canada could only use a…

Federal Court Makes Decision on Voluntary Disclosures

“No-names basis submission that was accepted by CRA cannot be disregarded by CRA afterwards if facts have…

Salaries & Bonuses To Family Members

“In-kind payments are acceptable and so are large bonuses to non-shareholder family members..” Two fairly recent cases…

Personal Health Service Plans – The Story Continues

“The health plan must be available to employees, not just shareholders..” The Tax Court has again looked…

Professional Corporations – Doctors and Dentists

“New rules allow for non-family members to be shareholders..” In the Ontario Budget tabled on May 11,…

Were They Thinking?

“Unfortunately, sometimes a case has to go to Court for the obvious result..” Mary Conroy appealed an…

Application of Fairness Provision in Court

“The fairness guidelines issued by CRA do not apply to the Courts..” A recent case dealt with…

Cadesky Tax Books

STEP CANADA/CRA Roundtables

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Trusts and International Tax Treaties

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Taxation of Real Estate in Canada

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Towards Greater Fairness in Taxation: A Model Taxpayer Charter

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Taxation of Trusts and Estates: A Practitioner’s Guide 2024

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Taxation at Death: A Practitioner’s Guide, 2021

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