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...
Taxation of Illegal Income: What Canadian Taxpayers Need to Know For obvious reasons, there is a tendency to conceal income derived from illegal activities from government authorities. However, there is no “pass” for failing to pay taxes owed to the Canada Revenue Agency (CRA) on such income. Taxpayers who...
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...