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...
Introduction – Employee Stock Options Certain corporations offer stock options to their employees as a form of compensation. Employee stock options give employees the right to purchase shares of their corporate employer for a fixed price during a set time period. If the value of the shares exceeds the...
Introduction: Cryptocurrency-Trading Businesses in Canada Canadian cryptocurrency-trading businesses face unique challenges. The mostly unregulated cryptocurrency, non-fungible token (NFT), and blockchain markets brings higher risk of fraud and cyber-crime. The developments in blockchain technology bring about an ever-increasing range of opportunities, arrangements, and assets—smart contracts, cryptocurrency liquidity mining and yield...
Overview – T1135 Reporting Requirement: Exception for Interests in Non-Resident Trusts Not Acquired for Consideration Canadian who own specified foreign property with a combined cost amount of at least $100,000 in a tax year is required to file a T1135 information return with his or her tax return which...