Archive for Author: taxlaw

Elderly couple reviewing paperwork in front of a laptop on a table.

A Canadian Tax Lawyer’s Guide to the Canadian Tax Treatment Of Domestic, Foreign Retirement Compensation Arrangements (RCAs) for High-Income Earners: Lessons from Martin v The King

Introduction: What is a Retirement Compensation Arrangement? Retirement planning is a cornerstone of long-term financial security, especially for high-income earners and corporate executives whose pensionable earnings often exceed the thresholds permitted under traditional retirement savings vehicles. One such advanced planning mechanism available in Canada is the Retirement Compensation Arrangement...

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Share Redemption and Share Retraction: Tax Treatment by CRA—plus they are Useful Tax Planning Tools

Introduction: What is Share Redemption? What is Share Retraction? Corporate structures in Canada often involve various strategies for managing share ownership, capital returns, and shareholder interests. Two important concepts in corporate law and taxation that frequently arise are share redemption and share retraction. Share redemption occurs when a corporation...

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Tax Court of Canada is not ‘Slap-Dash,’ nor Tolerates Sloppy Examination for Discovery: Whistler Blackcomb Holdings Inc. v The King, 2025, TCC 13: Expert Canadian Tax Litigation Lawyer

Introduction: Tax Litigation & Examination for Discovery The Tax Court of Canada, established in 1983 under the Tax Court of Canada Act, serves as a federal court that adjudicates disputes arising from tax matters between individuals or companies and the Canada Revenue Agency. The court’s jurisdiction primarily encompasses appeals...

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Man in a suit at a desk typing on a keyboard with a tax form on the monitor screen

What is the EFILE Program? Eligibility, Requirements, Obligations, and Revoking of Registration: A Guide for Accountants & Tax Preparers

What is EFILE, and which accounting firms, accountants are eligible to participate? EFILE is an electronic service that allows tax preparation service providers in Canada to file their clients’ tax returns with the Canada Revenue Agency (CRA) directly from their tax preparation software. To participate in the EFILE program, the...

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Older women at a Canada Day parade holding flags, one wearing a maple leaf jacket

How Are Foreign Pension Plans, Income from Foreign Pension Plans Treated by CRA in Canada? A Canadian Tax Lawyer Gives Inside Scoop

Introduction: Canadian Tax Treatment of Foreign Pension Plans and Income from Foreign Pension Plans is Complex and Fact-Specific The 2021 Canadian Census revealed that nearly a quarter of the Canadian population consisted of immigrants, which represents the eighth-largest immigrant population in the world. In 2022, Canada’s population grew by...

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What are the CRA Tax Breaks for Canadian Caregivers? Disability Tax Credit (DTC), Medical Expense Tax Credit (METC), and the Canada Caregiver Credit (CCC)

Introduction Caring for a loved one with a disability or chronic illness is often a labour of love, but it often comes with significant financial strain on top of the emotional burden. From preparing specialized meals to arranging therapy or hiring help, caregivers frequently shoulder costs that add up...

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