Single Purpose Corporations – New Proposals

“CRA has issued a new administrative policy on single purpose corporations that own US property..” In the…

CRA Disputes

“Information available for a notice of objection..” Whenever a taxpayer or his/her representative is dealing with the…

Allowable Business Investment Losses

“Issues To Consider.” A business investment loss (BIL) arises from a disposition to which subsection 50(1) applies…

Fairness Rules – December 2004 Deadline

“All files should be checked..” Generally speaking, the Fairness Rules allow the Canada Revenue Agency discretion to…

Residency Test

“Tax treaties should be considered in determining whether an individual is resident in Canada..” In a recent…

Deductibility of Management Bonus

“Be aware of CRA policy on deductibility of management bonuses..” CRA tried to clarify its position on…

Withholding Tax For Services Done – By Non-Residents in Canada

“A 15% withholding tax may be payable for services rendered in Canada..” Regulation 105 states that every…

Deemed Association

“Shares held by trusts or minors could have adverse results for association purposes..” There are a number…

Attribution That Works

“Low Prescribed Rates Allow for Income Splitting.” The third quarter of prescribed rate has been set at…

Evidence Required

“Sometimes evidence accepted by Courts is different from the CRA..” A situation that many professionals face when…

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