Archive for Year: 2026

Critical Illness Insurance Tax Shelters in Canada: CRA Issues Warning on Aggressive Tax Schemes Involving Critical Illness Insurance Products and Tax-Free Corporate Funds Extraction

Overview of Critical Illness Insurance Tax Shelters and CRA Warnings for Canadian Entrepreneurs, Professionals, Investors, Accountants, and Crypto Investors In today’s complex Canadian tax environment, business owners and investors are increasingly encountering promotions for critical illness insurance tax shelters as a means to optimize corporate finances. These arrangements, which...

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A Canadian Tax Audit Compared with a Criminal Investigation: Important Differences and Legal Protections for Taxpayers in Gravel v. Agence du revenu du Québec

Tax Audits Versus Criminal Investigations As an experienced Canadian tax lawyer specializing in tax audits and tax investigations, I often advise clients on the critical distinctions between tax audits and criminal investigations under Canadian tax legislation, whether conducted by the Canada Revenue Agency (CRA) or Revenu Québec. The recent...

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Want Provincial Tax Relief? You Must File Appeals in the Right Court (Even CRA Gets it Wrong)

Court jurisdiction in Canadian tax disputes remains a persistent challenge for taxpayers who face assessments involving both federal and provincial income tax. The distinction becomes especially significant when the CRA assesses an individual’s provincial tax obligations based on the agency’s view of the taxpayer’s province of residence. The recent...

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How to Transfer a UK Pension Plan to a SIPP, to Avoid Undesirable Tax Consequences to CRA—Guidance from a Canadian Tax Lawyer

In November 2022, the Canada Revenue Agency (CRA) addressed questions concerning the Canadian income tax implications of transferring the commuted value of benefits from a UK defined-benefit pension plan (“UK DB Plan”) to a self-invested personal pension (“UK SIPP”) by a Canadian tax resident.  Specifically, the inquiry focused on...

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