Jan 19, 2022
As we advised in Tax Tip 20-04 , significant additional disclosure and filing requirements for trusts were announced in the 2018 Federal Budget and are scheduled to apply for trust’s 2021 and subsequent tax years.
Nov 16, 2021
The Disability Tax Credit Promoters Restrictions Act (the “DTCPRA”) was adopted by Parliament allegedly to protect “vulnerable Canadians” from perceived abusive fees some “promoters” were believed to be charging to assist taxpayers in accessing the disability tax credit (“DTC”).
Apr 19, 2021
As you may know, we have supported a request to the CRA to extend the April 30 deadline to June 15. But if the deadline is NOT extended, here are some practical tips to reduce the burden of a COVID tax season.
Oct 09, 2020
As part of the Canadian government’s efforts to combat money laundering, aggressive tax avoidance and tax evasion activities relating to trusts, enhanced income tax reporting requirements for certain trusts will be required for the 2021 and subsequent taxation years. The new rules also contain harsh penalties for knowingly fail to comply with the new trust reporting requirements or non-compliance due to gross negligence…
Jul 29, 2020
On July 27, 2020, the Canada Revenue Agency (the “CRA”) announced a further extension to the tax payment and filing due dates for certain taxes from September 1, 2020 to September 30, 2020. The extension applies to current year individual, corporate, and trust tax returns, as well as instalment payments. Interest will not be charged on these amounts if payments are made by the extended deadline of September 30, 2020. Whether or not full payment is required in order to receive this relief is unclear.
Apr 15, 2020
The Canada Emergency Wage Subsidy (“CEWS”) legislation has been released and is now law. In general, the CEWS will reimburse eligible employers 75 per cent of the amount of remuneration paid to eligible employees (to a maximum benefit of $847 per week).
The legislation was prepared under less than ideal circumstances so it is not surprising that there are a number of questions and observations we hope the government will address. However, we can now provide more answers than in our April 7, 2020 Tax Tip.
Apr 07, 2020
The Federal government recently announced a number of measures to assist Canadians during the current COVID-19 crisis. Two measures were introduced to assist businesses with retaining, rather than laying off, employees.
The 10% Temporary Wage Subsidy (“TWS”) is a three- measure that will allow eligible employers to reduce the amount of payroll deductions required to be remitted to the Canada Revenue Agency (the “CRA”). The subsidy is 10% of remuneration paid by eligible employers (from March 18, 2020 to June 19, 2020) of up to $1,375 per employee, and a maximum of $25,000 per employer. Given its limited value, Canadians were disappointed with this support program.
Dec 02, 2019
It is well understood that qualified donations made by an individual generate donation tax credits in the year the donation is made or the subsequent five taxation years. What are less known are donation “carryback” rules that are available when a donation is made in the year of an individual’s death or some of the subsequent years.
Nov 18, 2019
Rectification, in simple terms, is a legal process where an entity petitions the court to change previously executed written documents. In the tax world, rectification may be used by a taxpayer to change the terms of a legal document to alter the tax results of a transaction, but is generally regarded by practitioners as a bit of a “Hail Mary” as it is an expensive and time consuming exercise with uncertain results. The fact that the threshold for granting a rectification order is quite high does not help the cause. This threshold was further elevated by the judgement in Fairmont Hotels, 2016 SCC 56, which narrowed the scope of rectification. However, it appears that at least one provincial court is showing a willingness to interpret the tests laid out in Fairmont in a taxpayer friendly manner.
Nov 01, 2019
The principal residence exemption allows Canadians to reduce or eliminate Canadian income tax on gains resulting from the disposition of a home or vacation property a Canadian “ordinarily inhabits”. Eligibility for the exemption is being scrutinized more than in the past, by the CRA.
Sep 20, 2019
HWTs must conform to the Private Health Service Plan rules in the Income Tax Act as well as CRA administrative rules. In theory, a HWT allows a company to deduct payments to fund the HWT and the shareholder/employee is not taxable on eligible medical expenses reimbursed to him or her by the HWT.
Sep 09, 2019
A non-resident of Canada is subject to Canadian taxation on gains arising from the disposition of taxable Canadian property (“TCP”). TCP includes many items but the most common one we see in practice is Canadian real estate. Many non-residents selling Canadian real property often discover the purchaser is withholding 25% of the gross proceeds pending receipt of a “compliance certificate” from the non-resident. In some cases, the withholding is 50%. Our discussion today focuses on a non-resident’s reporting and withholding tax requirements under section 116 of the Income Tax Act (the “Act”) upon the sale of TCP and more importantly, how to reduce the withholding tax amounts.
Aug 26, 2019
It is not uncommon for the sale price of a business to be partially based on future events. In these cases, an earnout is often used as a mechanism to determine a portion of the sale price based on achieving certain results for a period of time after closing of the sale. For example, the parties may agree to an initial sale price of $5,000,000, with an additional $100,000 per year in any of the subsequent 5 years, if revenues increase by at least 5% in the year. To keep things “simple” we will assume shares, not assets, are being sold.
Aug 12, 2019
Occasionally, a taxpayer moves from his/her principal home into a new home and rents the old home out, or converts part of the home for a different purpose. Alternatively, he/she may move into one of his/her rental properties and turns it into a principal home. While this may not be an issue if the change is short term and temporary, a permanent change could give rise to a deemed disposition of the property for tax purposes. If not carefully managed, this deemed disposition can create undesirable results for these taxpayers.
Jul 26, 2019
In accordance with regulation 200(1) of the Income Tax Act, every person paying commissions, fees or other amounts for services shall report these payments on a prescribed information return (i.e., the T4A slip). Over the years, the Canada Revenue Agency (the “CRA”) has not provided clear guidance on how the fees are to be reported on the T4A slip.
Jul 12, 2019
The use of creative international structures by multinational corporations to transfer a significant portion of their global profits to low tax jurisdictions led the Organisation of Economic Co-operation and Development (“OECD”) to undertake the Base Erosion and Profit Shifting (“BEPS”) study. The study concluded with 15 proposed initiatives, one of which is to address potentially abusive use of tax treaties between countries to shift profits.
Jun 27, 2019
The Income tax act contains a number of anti-avoidance provisions. Subsection 55(2) apples to convert some intercorporate actual or deemed dividends into capital gains or proceeds of disposition, respectively..
This provision was created when capital gains tax rates were higher than dividends. The intent of the section is to allow companies to move their tax paid retained earnings (“Safe Income”) out of, say, an operating company to a holding company, tax free since intercorporate dividends of this nature are often tax free. There is no further tax paid until the amounts are paid out as dividends to a shareholder who is a “natural person” where the amounts are taxed as eligible or “ineligible” dividends.
Feb 26, 2019
A Canadian corporation’s first fiscal year can end up to 53 weeks after the date of incorporation. Once the fiscal period has been chosen, it cannot be changed, unless by operation of law, without the permission of the Canada Revenue Agency (“CRA”).
Feb 05, 2019
Form T1134, Information Return Relating to Controlled and Non-Controlled Foreign Affiliates is a foreign reporting form which must be filed by all Canadian resident taxpayers (corporations, individuals and trusts), and partnerships for any year in which the taxpayer has an interest in a controlled or non-controlled foreign affiliate, at any time in the year.
Jul 19, 2017
“Changes to strategies that have been the basis for shareholder… Read more »
Jul 10, 2017
“relief from penalties will be significantly curtailed” The Voluntary Disclosures… Read more »
Oct 03, 2016
the CRA views these entities to be corporations for Canadian… Read more »
Jul 20, 2016
taxpayers may need to act now Prior to 2011, upstream… Read more »
Jan 11, 2016
“the initial submission can be made quickly, on a no-names… Read more »
Nov 20, 2015
“Only new stock options affected by tax changes”, says Minister… Read more »
Nov 17, 2015
“The expected increase in personal tax rates is significant and… Read more »
Sep 22, 2015
“In order for the election to be valid each… Read more »
Aug 25, 2015
“The re-contribution must be made before March 1, 2016” Generally,… Read more »
Jul 13, 2015
“A small change to timing can have a big tax… Read more »
Jun 15, 2015
“LLC’s may not be the best vehicles for cross-border planning”… Read more »
Feb 24, 2015
“securities held in a Canadian brokerage account or registered plan… Read more »
Jan 05, 2015
“The transfer need not be made with the intention of… Read more »
Dec 29, 2014
As was mentioned in last week’s Tax Tip, new legislation… Read more »
Dec 22, 2014
“We encourage you to speak with your tax advisor regarding… Read more »
Dec 09, 2014
“the immigrant trust exemption was withdrawn.” For forty years, Canada… Read more »
Dec 01, 2014
“the ability to make this election ends this year.” Typically,… Read more »
Nov 24, 2014
“There is no set hierarchy of factors that one can… Read more »
Nov 10, 2014
“A DPSP may be a better way to create a… Read more »
Nov 03, 2014
“it is a good idea to start the process now.”… Read more »
Oct 28, 2014
“After December 31, 2015, all unfiled elections will be invalid.”… Read more »
Oct 20, 2014
“It is common for individuals to include charitable bequests in… Read more »
Oct 14, 2014
“it is better to start planning now, rather than waiting.”… Read more »
Oct 06, 2014
“we expect that the changes will eliminate an important tax… Read more »
Sep 22, 2014
On August 29, 2014, the Department of Finance released a… Read more »
Sep 16, 2014
“The Transferee can be assessed even if he or she… Read more »
Jul 03, 2014
“Capital gains exemption planning is complicated.” A Canadian individual is… Read more »
Jun 27, 2014
“the voluntary compliance window is closing.” On June 18, 2014,… Read more »
Jun 20, 2014
“If payroll taxes apply, the breakeven point will be even… Read more »
Jun 10, 2014
“For tax purposes, the answer is very important.” For tax… Read more »
May 28, 2014
“Detection is not as hard as it used to be.”… Read more »
Mar 25, 2014
“we suggest that… you make note of and track the… Read more »
Mar 04, 2014
“we do not think they go far enough and are… Read more »
Feb 18, 2014
“there will be fewer places for U.S. persons to hide.”… Read more »
Feb 03, 2014
“the Government of Canada is serious about enforcing tax compliance.”… Read more »
Jan 20, 2014
“Seriously consider implementing the plan before the end of March… Read more »
Dec 16, 2013
“If the charitable tax shelter seems too good to be… Read more »
Nov 18, 2013
“Consideration should be given to paying out capital dividends before… Read more »
Nov 11, 2013
“If commercially practical structure a partial sale of Qualifying Property… Read more »
Oct 28, 2013
“The actual process of classifying an entity for Canadian tax… Read more »
Oct 18, 2013
“Consider paying planned dividends by the end of 2013.” This… Read more »
Oct 11, 2013
“the CRA is now targeting those who receive payments from… Read more »
Oct 04, 2013
“Some Important Points for the Adviser to Consider.” Many individuals… Read more »
Sep 06, 2013
“One of the important roles of tax advisors is to… Read more »
Aug 16, 2013
“the real benefit is the ability to increase the spread… Read more »
Aug 02, 2013
“the tax and estate planning landscape will be significantly changed… Read more »
Jul 26, 2013
“the clock is ticking for offshore investors.” The Voluntary Disclosures… Read more »
Jun 28, 2013
“The level of detail required has been vastly expanded.” In… Read more »
Jun 14, 2013
“The payor need not be resident in Canada.” As discussed… Read more »
May 31, 2013
“please consult your TSG representative if you have a ‘moving… Read more »
May 17, 2013
“your assets or earnings may be seized to pay the… Read more »
May 03, 2013
“as long as Canadian tax rules are followed.” The media… Read more »
Mar 15, 2013
“The benefit of this strategy is in the use of… Read more »
Feb 22, 2013
“auditors do not seem to be evaluated based on the… Read more »
Jan 25, 2013
“if it seems ‘too good to be true’, then it… Read more »
Jan 11, 2013
“Congress still has to deal with spending cuts.” Over New… Read more »
Dec 28, 2012
“An insurance trust is generally funded outside the estate.” A… Read more »
Dec 21, 2012
“the overall cost of EI premiums can be significant.” Family-owned… Read more »
Dec 07, 2012
“Immediate action may be necessary to take advantage of the… Read more »
Nov 30, 2012
“audits of HNW individuals still remain a high priority.” At… Read more »
Nov 23, 2012
“it is a good idea to review upcoming SR&ED expenditures… Read more »
Nov 16, 2012
“partnerships are still a useful vehicle.” A partnership is a… Read more »
Nov 09, 2012
“The CRA will neither issue a refund nor assess the… Read more »
Nov 02, 2012
“It is important to remember the interaction of ABILs and… Read more »
Oct 26, 2012
“Rollovers of Retirement Plan funds are not only available to… Read more »
Oct 19, 2012
“Generally, bursaries are included in income and a deduction for… Read more »
Oct 12, 2012
“this is not the last word on the matter.” Section… Read more »
Oct 05, 2012
“in many cases a portion of existing debt can be… Read more »
Sep 29, 2012
“the SCC corrected its previous interpretation of the combination test.”… Read more »
Sep 21, 2012
“These procedures became effective on September 1, 2012.” In Tax… Read more »
Sep 12, 2012
“Residency is based on common law and case law.” Many… Read more »
Sep 07, 2012
“a taxpayer can opt out of this “rollover” rule.” When… Read more »
Aug 31, 2012
“The ability for a family member to use RRSP funds… Read more »
Aug 24, 2012
“it may be beneficial for non-residents to exercise their employee… Read more »
Aug 17, 2012
“Identifying eligibility for the DTC can result in thousands of… Read more »
Aug 10, 2012
“Tax practitioners often recommend the use of trusts.” Tax practitioners… Read more »
Aug 03, 2012
“the small supplier limit is not measured based on taxable… Read more »
Jul 27, 2012
“relief from some of the stringent administrative requirements.” We recently… Read more »
Jul 13, 2012
“certain alterations to a home or incremental construction costs may… Read more »
Jul 06, 2012
“the new procedures should provide some relief.” On June 26,… Read more »
Jun 29, 2012
“It is also important to consider the various attribution rules… Read more »
Jun 15, 2012
“most countries have legislation permitting the enforcement of foreign judgments.”… Read more »
Jun 08, 2012
“These new rules should generally provide greater flexibility.” Since the… Read more »
Jun 01, 2012
“In a typical family estate freeze, this anti-avoidance rule will… Read more »
May 25, 2012
“The ‘prohibited investment’ rules… have significantly impacted RRSP and RRIF… Read more »
May 18, 2012
“The type of investor can also impact whether an ABIL… Read more »
May 11, 2012
“Post Mortem Pipeline Transactions.” As discussed in Tax Tip 10-13,… Read more »
May 04, 2012
“Residence of Trusts.” The Supreme Court of Canada recently confirmed… Read more »
Mar 16, 2012
“There are two changes in this revised version of T5013… Read more »
Mar 09, 2012
“it is desirable to minimize the employment benefit and increase… Read more »
Mar 02, 2012
“Your TSG members will be reviewing and analyzing the 2012… Read more »
Feb 17, 2012
“Advisors should review these new rules with clients who are… Read more »
Feb 10, 2012
“”The timing of the RRSP deduction can result in significant… Read more »
Feb 04, 2012
“CRA Revises Joint Venture Administrative Policy.” The Canada Revenue Agency… Read more »
Jan 27, 2012
“These new rules have an impact on remuneration planning for… Read more »
Jan 20, 2012
“continuing to delay or ignore any catch up U.S. filings… Read more »
Jan 06, 2012
“”non-filers can take some comfort that they will not automatically… Read more »
Dec 23, 2011
“If the charitable tax shelter seems too good to be… Read more »
Dec 09, 2011
“The tax cost plus interest and penalties for non-reporting can… Read more »
Dec 02, 2011
“Often the negative consequences can be avoided by delaying the… Read more »
Nov 25, 2011
“To qualify, the plan must be made available to all… Read more »
Nov 18, 2011
“The prescribed rate does not fluctuate over the deferral term.”… Read more »
Nov 11, 2011
“amounts paid to grandparents could qualify.” The Income Tax Act… Read more »
Nov 04, 2011
“technical amendments will eliminate any current deferral opportunities with PSB’s.”… Read more »
Oct 28, 2011
“Waiver requests are not usually granted retroactively.” Regulation 102 requires… Read more »
Oct 21, 2011
“”non-capital losses often include losses from property”.” The Income Tax… Read more »
Oct 14, 2011
“Most tax preparation software does not update instalment schedules..” For… Read more »
Oct 07, 2011
“they would appear to apply to crystallization transactions.” The Income… Read more »
Sep 30, 2011
“”accessing the exemption through a trust is not always possible”.”… Read more »
Sep 16, 2011
“Section 84.1 assessments are a major cause of litigation.” Section… Read more »
Sep 12, 2011
“We have found that the CRA is using schedule 91… Read more »
Aug 22, 2011
“the guaranteed current use of the donation receipt makes the… Read more »
Aug 12, 2011
“”second generation” income is not attributed back to the original… Read more »
Aug 05, 2011
““It is uncertain if the IRS will continue to assess… Read more »
Jul 29, 2011
“CRA expects taxpayers to comply with draft legislation.” Proposed changes… Read more »
Jul 22, 2011
“an individual will be able to carry forward unused grant… Read more »
Jul 15, 2011
“GST/HST may apply to other services provided by a practitioner.”… Read more »
Jul 08, 2011
“The employer must calculate, withhold and remit tax based on… Read more »
Jun 24, 2011
“This creative estate planning technique can create a legacy of… Read more »
Jun 17, 2011
“The ten-year rule refers to the years during which the… Read more »
Jun 10, 2011
“Penalties may be eliminated.” In Tax Tip 11-05 we reported… Read more »
Mar 18, 2011
“Income earned in a TFSA is taxable on a current… Read more »
Mar 04, 2011
“One can never know for sure which way the Tax… Read more »
Feb 18, 2011
“These changes will make it easier for the IRS to… Read more »
Feb 11, 2011
“The IRS believes the 2011 initiative offers clear benefits.” On… Read more »
Feb 04, 2011
“The election is invalid on a go-forward basis.” Canadian residents… Read more »
Jan 28, 2011
“It may save time and effort for such a CCPC… Read more »
Jan 21, 2011
“it is important to plan in advance.” There are a… Read more »
Jan 07, 2011
“If these special deadlines are not met on the wind-up… Read more »
Dec 17, 2010
“Experimental procedures that are not available locally can be eligible.”… Read more »
Dec 10, 2010
“The Canada Revenue Agency has been attacking claims of Canadian… Read more »
Dec 03, 2010
“such trusts provide for incapacity planning” While an earlier Tax… Read more »
Nov 12, 2010
“It is uncertain whether the CRA’s policy is correct, as… Read more »
Oct 22, 2010
“IFRS would require a previously unnecessary tax adjustment.” All Canadian… Read more »
Oct 08, 2010
“Even though late filing of the form is allowed, it… Read more »
Sep 23, 2010
“Partnerships that never filed before may now have to.” The… Read more »
Sep 14, 2010
“Most employers will not want to elect out of the… Read more »
Aug 31, 2010
“relief from one provision of the ITA does not mean… Read more »
Aug 25, 2010
“initially structuring the business as a sole proprietorship or partnership…… Read more »
Aug 13, 2010
“build flexibility into the deceased’s Will.” People often make their… Read more »
Aug 09, 2010
“relief from the tax on departure may be available.” Upon… Read more »
Jul 30, 2010
“An ABIL claimed by a corporation reduces the corporation’s CDA.”… Read more »
Jul 09, 2010
“the result can be the equivalent of ‘triple tax’.” The… Read more »
Jul 02, 2010
“”asset-building” can be particularly effective.” A “spouse trust” can be… Read more »
Jun 25, 2010
“Such a trust can provide estate planning benefits” Canadian residents… Read more »
Jun 18, 2010
“potential pitfalls can result in unexpected, costly mistakes.” Capital gains… Read more »
Jun 04, 2010
“X will lose out on claiming $60 of available losses… Read more »
May 28, 2010
“sometimes traditional planning techniques become outdated.” As we alluded to… Read more »
May 21, 2010
“The penalty could apply on a per-item basis.” Over the… Read more »
May 14, 2010
“”the combined tax bill can be significantly lower than the… Read more »
May 07, 2010
“The 2010 Federal Budget proposes to repeal the employee stock… Read more »
Mar 22, 2010
“If Mr. X had retained and sold the investment, there… Read more »
Mar 12, 2010
“Loans to non-residents can cause income inclusions.” Subsection 17(1) of… Read more »
Feb 26, 2010
“This withholding tax requirement is often overlooked.” In a recent… Read more »
Feb 12, 2010
“Early identification and good documentation are critical.” The Scientific Research… Read more »
Feb 05, 2010
“Form T1135 includes a certificate of full disclosure to be… Read more »
Jan 29, 2010
“U.S. status could eliminate many Canadian tax benefits.” Canada taxes… Read more »
Jan 22, 2010
“The CRA has decided to actively audit domestic inter vivos… Read more »
Jan 15, 2010
“Using an RRSP as security for a loan may be… Read more »
Jan 08, 2010
“Two deductions may be available to individuals.” Two deductions may… Read more »
Dec 18, 2009
“Identifying unreported capital losses from prior years can result in… Read more »
Dec 14, 2009
“Part of the gain may be exempt from Canadian tax.”… Read more »
Dec 11, 2009
“The decision whether to elect out of the spousal rollover… Read more »
Nov 16, 2009
“When assets are jointly titled, they do not pass through… Read more »
Nov 06, 2009
“You should consider creating a testamentary trust as part of… Read more »
Oct 30, 2009
“It may be advisable for the lender to charge a… Read more »
Oct 23, 2009
“The Canada Revenue Agency (CRA) has announced policy changes for… Read more »
Oct 16, 2009
“There is no prescribed form for the 50(1) election.” The… Read more »
Oct 09, 2009
“‘it is a good idea to start the process now’.”… Read more »
Sep 25, 2009
“Businesses that purchase equipment or other capital goods that bear… Read more »
Sep 11, 2009
“The transfer need not be made with the intention of… Read more »
Aug 10, 2009
“Do not be surprised if the rebate claim is denied.”… Read more »
Jul 24, 2009
“The $10,000 penalty will be assessed automatically against corporate taxpayers.”… Read more »
Jun 19, 2009
“A taxpayer can object to a notice of assessment even… Read more »
Jun 08, 2009
“The IRS announced that it is suspending the expanded definition… Read more »
May 15, 2009
“The ITN is a nine-digit number issued by the CRA… Read more »
May 08, 2009
“The eligibility for the higher CCA rate is not automatic.”… Read more »
Apr 09, 2009
“The CRA will authorize a reduction in tax withheld if… Read more »
Apr 03, 2009
“The credit for foreign taxes will likely be based on… Read more »
Mar 27, 2009
“Make sure the correct amount of interest is paid by… Read more »
Mar 20, 2009
“Where expenses are significant, the savings outweigh the costs.” Most… Read more »
Mar 13, 2009
“If you own more than one property, keeping track of… Read more »
Mar 06, 2009
“It may be prudent to consider paying a capital dividend… Read more »
Feb 27, 2009
“The rule of thumb is to invest in an RRSP… Read more »
Feb 20, 2009
“Equity may include inherent goodwill that is not reflected on… Read more »
Feb 13, 2009
“This election will not be available on property held in… Read more »
Feb 06, 2009
“The TFSA program offers taxpayers an opportunity to earn investment… Read more »
Jan 28, 2009
“You should be aware of the expanded base of those… Read more »
Dec 05, 2008
“The failure to elect out of subsection 256(9) can result… Read more »
Nov 28, 2008
“Eligible pension income relating to the portion of the year… Read more »
Nov 07, 2008
“Don’t Ignore the Proposed Restrictive Covenant Legislation.” The restrictive covenant… Read more »
Sep 19, 2008
“The CRA website may refer to the new requirements but… Read more »
Aug 15, 2008
“Be sure before concluding that the PSB rules do not… Read more »
Aug 01, 2008
“Transfer to the guardian for an incapacitated child will not… Read more »
Jul 18, 2008
“Start the clock ticking by filing a T5013.” Partnerships do… Read more »
Apr 11, 2008
“Opportunities for your clients.” Many professionals are not well versed… Read more »
Mar 07, 2008
“Investment income can reduce a company’s ability to claim refundable… Read more »
Feb 08, 2008
“Complicated rules for a simple situation.” When an individual moves… Read more »
Jan 25, 2008
“Old rules of thumb need to be re-examined carefully.” The… Read more »
Jan 18, 2008
“Sale of sole proprietor can be tax-free with planning.” The… Read more »
Dec 14, 2007
“Elimination of withholding tax will apply to interest payments by… Read more »
Dec 10, 2007
“Whether an amalgamation or a wind-up is chosen, the tax… Read more »
Dec 03, 2007
“The processing time of voluntary disclosures will be increased without… Read more »
Nov 23, 2007
“Shares of foreign corporations may render a corporation ineligible for… Read more »
Nov 09, 2007
“The revised Protocol provides a mechanism for allocating stock option… Read more »
Nov 02, 2007
“Proper planning can result in benefits to both sides.” On… Read more »
Oct 05, 2007
“Tax treatment does not automatically follow the accounting treatment for… Read more »
Jun 15, 2007
“Filing the appropriate elections is necessary to ensure that an… Read more »
Jun 08, 2007
“Proper planning can result in benefits to both sides.” When… Read more »
Mar 16, 2007
“Having a business transaction may preclude GAAR when tax is… Read more »
Mar 09, 2007
“File early to allow CRA enough time to confirm all… Read more »
Mar 02, 2007
“The CRA will use GAAR to overcome a decision they… Read more »
Feb 23, 2007
“The CRA can reallocate partnership income allocations when they consider… Read more »
Feb 16, 2007
“The transit pass credit is for 2006 and the fitness… Read more »
Jan 26, 2007
“The allocation of purchase price is important on the purchase… Read more »
Jan 19, 2007
“Attribution can be avoided on spousal loans in certain situations.”… Read more »
Dec 29, 2006
“CRA gives guidance on 2006 and 2007 eligible dividend designations.”… Read more »
Dec 22, 2006
“Inter-company dividends must be reviewed carefully for years between 2000… Read more »
Dec 15, 2006
“Refunds could be unexpectedly withheld.” The CRA recently sent out… Read more »
Dec 08, 2006
“Without planning, non-resident employers could be subject to unexpected taxes.”… Read more »
Dec 01, 2006
“Taxation of disbursements depends on whether the professional is an… Read more »
Nov 24, 2006
“Facts are key to determine tax treatment of share sales,… Read more »
Nov 10, 2006
“New rules for income trusts and pension income.” The Federal… Read more »
Nov 03, 2006
“In some cases, assets can, or must, be placed in… Read more »
Oct 27, 2006
“Capital cost allowance on rental properties can be restricted to… Read more »
Oct 20, 2006
“In some cases, meals and entertainment expenses can be 100%… Read more »
Oct 13, 2006
“Capital Gains are taxable over five or ten years depending… Read more »
Oct 06, 2006
“There can be a high cost to purchasing ineligible investments… Read more »
Sep 29, 2006
“You do not need to complete T2091 unless there is… Read more »
Sep 22, 2006
“CRA loses landmark case on application of GAAR to an… Read more »
Sep 15, 2006
“Can an accountant’s gross negligence transfer to the client?.” In… Read more »
Sep 08, 2006
“Ontario has decided to gradually introduce the reduced dividend tax… Read more »
Aug 11, 2006
“Bookkeeping errors to the benefit of a shareholder are not… Read more »
Aug 04, 2006
“A loss determination cannot be used to claim losses not… Read more »
Jul 21, 2006
“An individual’s residency often depends on his ties to a… Read more »
Jul 14, 2006
“In determining tax liability under s. 160, non-monetary transfers must… Read more »
Jul 07, 2006
“Past History and intention is relevant in determining if company… Read more »
Jun 30, 2006
“If you receive tax advice and disregard it, you are… Read more »
Jun 23, 2006
“What is required to determine when a debt is uncollectible?.”… Read more »
Jun 16, 2006
“Do you need a physical presence to be eligible for… Read more »
Jun 09, 2006
“Subsection 60(o) allows for the deductibility of legal payments for… Read more »
May 05, 2006
“The 2006 Budget has clarified how eligible dividends will be… Read more »
Mar 24, 2006
“Do you have clients who have commercial tenants who pay… Read more »
Mar 17, 2006
“Holding companies cannot be used to hold shares of a… Read more »
Mar 10, 2006
“Late-filing penalties were referred back to CRA because all taxes… Read more »
Mar 03, 2006
“Payments to an employment consultant are not permissible deductions from… Read more »
Feb 24, 2006
“Using attribution to your benefit is not GAAR.” In the… Read more »
Feb 10, 2006
“The due date of corporate taxes depends on many factors.”… Read more »
Feb 03, 2006
“There are new changes to the OBCA allowing family members… Read more »
Jan 27, 2006
“Payments to individuals on behalf of companies may still be… Read more »
Jan 20, 2006
“CDA payments related to ECE cannot be paid until the… Read more »
Jan 13, 2006
“The CRA has revised their policy on payments to non-resident… Read more »
Dec 16, 2005
“The Evans case clarifies the practical application of GAAR.” A… Read more »
Dec 02, 2005
“The new dividend tax rates will affect owner/manager clients.” On… Read more »
Nov 25, 2005
“Proposed Amendments to deny stock option benefit in ITC calculation.”… Read more »
Nov 18, 2005
“If CRA does not consider all facts, the courts are… Read more »
Nov 11, 2005
“Control in fact must be determined by considering all relevant… Read more »
Nov 04, 2005
“Can a taxpayer deduct an amount he didn’t pay directly?.”… Read more »
Oct 28, 2005
“A change of trustees could result in a change of… Read more »
Oct 21, 2005
“Ownership by a spouse does not preclude CCA and related… Read more »
Oct 14, 2005
“There is a 90-day limit to disclose the taxpayer’s name.”… Read more »
Sep 30, 2005
“Be aware of using U.S. LLC’s to hold shares in… Read more »
Sep 23, 2005
“Detailed records are necessary to calculate the cost base of… Read more »
Sep 16, 2005
“EPSP’s do not work in all situations.” There have been… Read more »
Sep 09, 2005
“Stock option benefit can be used for ITC calculation.” The… Read more »
Aug 12, 2005
“The CRA lost their argument that country hotels are lodges.”… Read more »
Aug 05, 2005
“CRA lost in its approach that any transactions that reduce… Read more »
Jul 25, 2005
“Tax Court forced to take a second look at this… Read more »
Jul 15, 2005
“ABULC’s are cost-effective alternatives to NSULC’s.” Until May 2005, US… Read more »
Jul 11, 2005
“No-names basis submission that was accepted by CRA cannot be… Read more »
Jun 16, 2005
“In-kind payments are acceptable and so are large bonuses to… Read more »
Jun 03, 2005
“The health plan must be available to employees, not just… Read more »
May 27, 2005
“New rules allow for non-family members to be shareholders..” In… Read more »
Apr 08, 2005
“Unfortunately, sometimes a case has to go to Court for… Read more »
Apr 01, 2005
“The fairness guidelines issued by CRA do not apply to… Read more »
Mar 25, 2005
“A taxpayer is required to include the proper amount in… Read more »
Mar 18, 2005
“This issue requires a review of all relevant factors..” Whether… Read more »
Mar 11, 2005
“In order for a special transfer to be tax-free, the… Read more »
Mar 04, 2005
“Terminal losses in the first year of an estate can… Read more »
Feb 25, 2005
“Spousal transfers can result in transfer of cost base..” There… Read more »
Jan 28, 2005
“If the proper elections and arrangements are made, tax payments… Read more »
Jan 21, 2005
“CRA’s interpretation may not be same as the Tax Court’s..”… Read more »
Jan 14, 2005
“Treaty protection does not mean there are no US tax… Read more »
Jan 07, 2005
“Proposed rules allow post mortem estate planning..” Subsection 40(3.6) is… Read more »
Jan 02, 2005
“Donations must be to certain charities only, before January 12,… Read more »
Dec 10, 2004
“Un-presented cheques should not be included in taxable capital..” In… Read more »
Dec 03, 2004
“CRA has issued a new administrative policy on single purpose… Read more »
Nov 19, 2004
“Information available for a notice of objection..” Whenever a taxpayer… Read more »
Nov 12, 2004
“Issues To Consider.” A business investment loss (BIL) arises from… Read more »
Nov 05, 2004
“All files should be checked..” Generally speaking, the Fairness Rules… Read more »
Oct 22, 2004
“RESP’s – a good vehicle to save for a child’s… Read more »
Oct 15, 2004
“Tax treaties should be considered in determining whether an individual… Read more »
Oct 08, 2004
“Be aware of CRA policy on deductibility of management bonuses..”… Read more »
Sep 24, 2004
“A 15% withholding tax may be payable for services rendered… Read more »
Sep 17, 2004
“Shares held by trusts or minors could have adverse results… Read more »
Sep 03, 2004
“Low Prescribed Rates Allow for Income Splitting.” The third quarter… Read more »
Aug 06, 2004
“Sometimes evidence accepted by Courts is different from the CRA..”… Read more »
Jul 30, 2004
“There could be shareholder benefits and non-deductible payments for PHSP’s..”… Read more »
Jul 23, 2004
“Using a specified class of shares can disassociate companies..” There… Read more »
Jul 16, 2004
“For countries other than U.S., the foreign social security taxes… Read more »
Jul 09, 2004
“CRA has changed its administrative position for companies owning U.S…. Read more »
Jul 02, 2004
“Certain conditions are necessary to claim capital losses on loans… Read more »
Jun 25, 2004
“Taxpayers must ensure that they only pay the withholding rate… Read more »
Jun 18, 2004
“This Supreme Court case is relevant for the purchase of… Read more »
Jun 11, 2004
“Tax-free payments are permitted in certain situations..” There are few… Read more »
Jun 04, 2004
“It is important to carefully draft trusts to avoid unwanted… Read more »
May 28, 2004
“Self Benefit trusts may help those under 65 in dealing… Read more »
May 21, 2004
“Planning is required before the deemed disposition rules apply.” Most… Read more »
Apr 02, 2004
“Filing a Partnership ReturnEnsures Partnership Income becomesStatute-Barred.” A Canadian partnership… Read more »
Mar 26, 2004
“Shares or debt of corporations can be claimed as a… Read more »
Mar 19, 2004
“It is possible to restructure to allow a professional corporation… Read more »
Mar 12, 2004
“When interest is deductible within a partnership and financing fees… Read more »
Mar 05, 2004
“Be Aware of Changing a Principal Residence to Investment Property… Read more »
Feb 24, 2004
“Klotz Case Reviews Art Flips to Charities.” In a recent… Read more »
Jan 23, 2004
“Free Meals and Gifts.” There was a recent case (McGoldrick),… Read more »
Jan 16, 2004
“Advantages Received by the Donor.” Further to the recent Tax… Read more »
Jan 09, 2004
“Government has limited access to donation receipts..” On Friday December… Read more »
Dec 19, 2003
“Year-End Tips.” As we approach December 31st, it is time… Read more »
Dec 17, 2003
“Year-End Planning Considerations.” There may be taxpayers who have realized… Read more »
Nov 28, 2003
“Living together makes you married for tax purposes..” Being a… Read more »
Nov 21, 2003
“Circumstances where reserves cannot be claimed are extended..” In general,… Read more »
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Jan 19, 2022
As we advised in Tax Tip 20-04 , significant additional disclosure and filing requirements for trusts were announced in the 2018 Federal Budget and are scheduled to apply for trust’s 2021 and subsequent tax years.
Nov 16, 2021
The Disability Tax Credit Promoters Restrictions Act (the “DTCPRA”) was adopted by Parliament allegedly to protect “vulnerable Canadians” from perceived abusive fees some “promoters” were believed to be charging to assist taxpayers in accessing the disability tax credit (“DTC”).
Apr 19, 2021
As you may know, we have supported a request to the CRA to extend the April 30 deadline to June 15. But if the deadline is NOT extended, here are some practical tips to reduce the burden of a COVID tax season.
