Loss carryovers are an important tool that taxpayers can utilize to reduce their taxable income. When taxpayer incurs a loss, they can use the loss to offset income that would otherwise be taxable. The timing and nature of the...
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When a Tax-Free Savings Account (TFSA) is a Business & Stripped of Tax Benefits: A Case Comment on Ahamed v The King, 2023 TCC 17
In 2009, the Tax-Free Savings Account (“TFSA”) program was introduced by the federal government of Canada as a means to allow Canadian families and individuals to more responsibly plan for retirement or significant life purchases. As of 2009, Canadian...
Overview: Unique Tax Considerations for Shareholder-Employees of a Corporation It is not uncommon within incorporated family businesses or other closely-held private corporations for the shareholders of that business to also act as the employees of the corporation’s business. The...
Rectification Saves Taxpayers from Adverse Tax Consequences arising from Drafting Error: Sleep Country Canada Holdings & Sleep Country Canada Inc v AGC, 2022 ONSC 6103 – A Canadian Tax-Litigation Lawyer’s Analysis
Introduction: Rectification & Its Tax Consequences Rectification is an equitable remedy. It allows parties to correct drafting errors that would otherwise render a legal instrument incompatible with the agreement that the instrument was meant to document. In these cases,...
Federal Court granted CRA access to big box store’s client lists that may uncover tax fraud and evasion: Guidance from a Canadian tax lawyer on CRA’s power to compel third parties to disclose information
Big box store was ordered by the Federal Court to turn over its client lists to the CRA In November 2022, the Federal Court granted the CRA’s request to force J.D.Irving to turn over its clients’ data from January...
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