Decoding Article XIV(6): Can Canadians Really Reclaim Departure Tax Under the Canada–Barbados Treaty? Opportunities for tax planning are virtually limitless. Provided your strategy aligns with both the wording and purpose of applicable Canadian tax legislation (in order to avoid a GAAR attack), it will likely withstand any challenges. Tax...
On Aug 15, 2025, the Canadian Government, through its Ministry of Finance and National Revenue, released for public consultation draft proposals for legislation in order to implement some previously announced tax measures and changes. These tax changes are numerous; however, this article will discuss some notable ones. The notable...
An Overview of the Canada Revenue Agency’s Administrative and Enforcement Powers The Canada Revenue Agency (CRA) possesses a wide range of administrative and enforcement powers in carrying out its mandate as the nation’s tax authority. These powers are extensive and complex, making the guidance of an experienced tax lawyer...
Dividend Tax Planning in Canadian Private Corporations For Canadian entrepreneurs and owner-managers, extracting value from a corporation is a central issue in Canadian corporate dividends and dividend tax planning. The decision to receive Canadian corporate dividends is not merely about cash flow. It directly affects overall tax efficiency, compliance...
In a November 13, 2025, decision, Baxter I.C.I. Corp. v. Attorney General of Canada, 2025 FC 1816, the Federal Court dismissed an application for judicial review, upholding a Canada Revenue Agency (CRA) decision that refused to waive or cancel penalties and interest for the applicant corporation. The case reinforces...