Archive for Author: taxlaw

Smiling woman tax representative in a suit at a desk in front of a laptop.

CRA unveils new process for Canadian taxpayers to authorize their tax representatives to access their online CRA account using “Authorize a Representative”

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...

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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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