Overview – Why the Tax Treatment of Employment Settlements Matters Before the Agreement Is Signed Employment settlements are often negotiated as a gross dollar amount, but employees and employers usually care about the net result. A wrongful-dismissal settlement, severance package, human-rights settlement, harassment award, stock-option settlement, or payment in...
Overview – When Can the CRA Deny a Business Expense? Many Canadian business owners assume that if a business expense was actually incurred and was genuinely connected to earning business income, it will be fully deductible for income tax purposes. That assumption is not always correct. Even where an...
Quick Answer: What Is the Toronto Vacant Home Tax? The Toronto vacant home tax (VHT) is a 3 percent annual municipal tax applied to residential properties in Toronto that are vacant for more than six months in a calendar year. The rate was 1 percent when the program launched...
Overview- CRA Denies Charitable Donation Tax Credits in the GLGI Donation Tax Shelter Litigation Cassidy v. The King, 2026 TCC 97 , is a Tax Court of Canada decision addressing charitable donation tax credits, donative intent, and the doctrine of abuse of process in repeated tax litigation involving the...
Overview– Why the TOSI Rules Remain a Risk for Family Business Tax Planning The Tax on Split Income (TOSI) rules remain among the most complex and misunderstood areas of Canadian private corporation tax planning. Found in section 120.4 of the Income Tax Act, these rules were significantly expanded effective...
Arbitrage Betting and Prediction Markets in Canada: Who This Guide Is For This guide is written for two distinct audiences: casual participants who occasionally place opposing bets across platforms to capture a pricing gap, and organized arbitrage traders who systematically scan multiple bookmakers or prediction markets, use dedicated tools,...
Overview: Significant gross negligence penalties against a taxpayer who blindly relied on a fraudulent tax preparation scheme to claim fictitious business losses This case centers on the imposition of gross negligence penalties under subsection 163(2) of the Income Tax Act against the Appellant, Attila John Burzuk. The penalties were...
CRA Denied Your Business Loss? Immediate Steps for Entrepreneurs and Investors If the CRA denied your business losses, you are likely facing increased tax liability and uncertainty about how to dispute the CRA’s position. This situation typically arises following a tax audit or review, where the CRA concludes that...
Overview: CRA Reassessment of $36 Million in Feasibility Study Deductions — Deductibility, Transfer Pricing, and Part XIII Withholding Tax In ExxonMobil Canada Resources Company v. The King, 2026 TCC 42 , the Tax Court of Canada ruled that ExxonMobil Canada Resources Company (“ExxonMobil Canada”) could deduct more than...
Overview: The Capital vs. Income Distinction and Why It Costs Taxpayers Millions One of the most consequential and frequently litigated questions in Canadian real estate tax law is whether the proceeds from the disposition of real property are taxable as a capital gain or as ordinary business income. The...