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...
Requirements for Part XIII Withholding Tax on Canadian Interest to Non-Residents – A Toronto Tax Lawyer Guide Introduction – What is Withholding Tax on Interest Paid to Non Residents Under the Income Tax Act, a Canadian tax resident must pay tax on his or her worldwide income, while non-residents...
What is Canadian Departure Tax? When taxpayers emigrate from Canada, for tax purposes they are deemed to have disposed of their capital assets even though no assets are actually sold. Capital gains earned from the disposition of these assets will be taxed. This tax is known as departure tax...
Introduction – Repeated Failure to File Income Tax Penalty Under Canada’s income tax system, taxpayers are required to calculate, report and pay their taxes in accordance with the applicable deadlines. In particular, the deadline to file 2020 taxes is April 30th 2021 for individual taxpayers and June 15th 2021...
Introduction: The Canada Revenue Agency’s Overzealous Use of Gross-Negligence Penalties Gross-negligence penalties aim to punish taxpayers whose conduct “involves a high degree of negligence tantamount to intentional acting, an indifference as to whether the law is complied with or not”: Venne v R., 84 DTC 6247. As such, the amount...
Introduction: Derivative Tax Liability under Section 160 of the Income Tax Act & Transfers to Trustees Section 160 of the Income Tax Act is a tax collection tool. It thwarts a taxpayer who attempts to hide assets from a Canada Revenue Agency tax collector by transferring them to a...
Introduction – CRA’s Court Order against Coinsquare On September 18, 2020, the CRA filed a Federal Court application against Coinsquare in order to compell the Toronto-based cryptocurrency platform to disclose tax information related to its customers. We covered this issue in depth here (https://taxpage.com/articles-and-tips/cra-wants-coinsquare-to-disclose-confidential-client-info/) Following a Federal Court ruling...
What is a Tax Notice of Objection? A tax Notice of Objection is a formal dispute filed with the Canada Revenue Agency wherein the taxpayer appeals tax amounts assessed against the taxpayer by the Canada Revenue Agency. For example, a taxpayer may argue an auditor improperly imputed taxable income...
Introduction – Tax Remission Order Canada’s tax laws contain provisions that are carefully crafted and precisely designed to provide taxpayers with various avenues to resolve their tax issues. However, in certain circumstances, Canada’s tax laws do not provide for adequate relief, or the strict application of certain provisions can...