Improvements to the CRA Authorization Request Service in Represent a Client As part of the Canada Revenue Agency’s ongoing efforts to improve service delivery by making it faster, easier, and more secure for taxpayers and their representatives, the Canada Revenue Agency has enhanced the Alternative process for individuals’ Authorization...
Introduction: Arrears Interest and the Role of Statutory Triggers in Loss Utilization In Bank of Nova Scotia v His Majesty the King, the Federal Court of Appeal (FCA) confirmed the Tax Court’s decision that arrears interest could accrue until the date of a reassessment, even in situations where a...
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...
Navigating Common Canadian Tax Issues in the Platform Economy The rise of the platform economy, encompassing gig work, freelancing, online sales, and short-term rentals, has created new income opportunities for many Canadians. However, with these opportunities come income tax and GST/HST tax obligations that can be complex to navigate....
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...
Introduction – Limit on Losses from Shares Held as Capital Property Subsection 112(3) of the Income Tax Act is a stop-loss rule that limits losses from the disposition of shares held as capital property. This provision applies when a taxpayer disposes of a share that has paid a dividend...
Canadian tax evasion may lead to imprisonment of up to 2 years The Canada Revenue Agency (CRA) operates a dedicated unit known as the Criminal Investigations Program. This division is responsible for investigating tax fraud, tax evasion, and other tax-related offences. When appropriate, it refers tax evasion cases to...
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...
In April 2025, the Federal Court of Appeal delivered its judgment on Total Energy Services Inc. v HMK, 2025 FCA 77, upholding the decision of the Tax Court of Canada in 2024 TCC 12 in February 2024. This case affirms the application of the general anti-avoidance rule (GAAR) under...
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...