Introduction – The Canada Emergency Wage Subsidy Many Canadian businesses have been impacted by the ongoing COVID-19 pandemic. While many businesses are experiencing financial hardship, some of them are unable to pay their employee’s wages. In response, the Government of Canada introduced the Canada Emergency Wage Subsidy (CEWS) in...
RRSP and TFSA Over-Contribution Tax Each year individuals have a certain amount they can contribute to their Registered Retirement Savings Plan (“RRSP”) and Tax Free Savings Plans (“TFSA”) for the year known as “contribution room”. If an individual contributes an amount to his or her RRSP or TFSA which...
Introduction: The CRA’s Voluntary Disclosures Program The Voluntary Disclosures Program (VDP), also known as tax amnesty, is a program offered by the Canada Revenue Agency (CRA) that encourages a taxpayer to voluntarily come forward and disclose any inaccurate or unreported information concerning tax filings. A taxpayer who makes a...
Introduction: Why do private corporations receive Refundable Dividends? Canada’s Income Tax Act was originally drafted with three main principles in mind: equity, simplicity, and fairness. In essence, the overall goal of the Income Tax Act is to remove incentives or disincentives for structuring one’s affairs in a particular manner...
Cryptocurrency Reporting Requirements: OECD to Release Cryptocurrency Reporting Framework in 2021 The Organisation for Economic Co-operation and Development (“OECD”) is due to release a recommended policy framework for cryptocurrency reporting standards in the upcoming months. Currently, there is little cohesion or transparency among the treatment of cryptocurrencies across countries....
Merrill v R – tax guidance from an experienced Canadian tax lawyer with respect to failure to file tax returns In 2019, the Canada Revenue Agency (CRA) served Mr. Merrill with Notices of Requirement to file his personal income tax returns for the 2014 to 2017 taxation years by...
Introduction – Corporate Tax Arrangements of ViacomCBS ViacomCBS is a multinational media corporation that owns the rights to multiple blockbuster franchises including Teenage Mutant Ninja Turtles, SpongeBob and Transformers. According to the New York Times, ViacomCBS is under scrutiny for allegations that the media conglomerate has been going to...
T1134 Form – Introduction by Toronto Tax Lawyer The Canadian Income Tax Act levies income tax on the worldwide income of resident Canadians. Multinational business structures are efficient, from both an operational and financial standpoint, and are often necessary in order to transact with certain entities located outside Canada. However,...
Introduction – What are Taxable Benefits Under Paragraph 6(1)(a) of the Income Tax Act, a taxable benefit is any advantage or benefit given to an employee from an employer, as well as the employee’s non-arm’s length parties such as his or her children or spouse. A taxable benefit must...
Introduction: What is “Rescission”? Rescission allows for a transaction to be retroactively cancelled, annulled, or set aside in circumstances where there has been a unilateral mistake by parties. In order to qualify for rescission as a remedy, the mistake must have created some injustice for the transacting parties. If...