Archive for Author: taxlaw

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Statute-Barred Tax Years and the Canada Revenue Agency’s Powers to Reassess Tax Years: A Canadian Tax Lawyer’s Guide

Introduction – What are Statute-Barred Tax Years? The Canadian tax system is based on the principles of self-assessment, which requires that Canadian taxpayers perform their own due diligence and to report their taxable income to the Canada Revenue Agency (“CRA”) for tax assessment. Under subsection 152(1) of the Canadian...

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Foreign Property Reporting Requirements and PayPal Accounts: A Canadian Tax Lawyer’s Guide

Introduction – Digital Payment Services and Financial Reporting Obligations Digital payment services like those offered by PayPal, which are used to facilitate money transfers domestically and internationally, are now well-integrated into our personal and professional lives. Whether your PayPal account is used for genuine commercial purposes, however, or for...

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T1135s, Beneficial Ownership of Property, and Chan v The Queen: A Canadian Tax Lawyer’s Case Comment

Introduction – T1135s and Beneficial Ownership The Canadian Income Tax Act requires that Canadian tax residents who own “specified foreign property” with a cost of $100,000 or more in Canadian dollars file an annual Foreign Income Verification Statement, or “T1135”, with that year’s tax return. Specified foreign property as...

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A picture of unpaid taxes by a director with a post it note on a laptop reading ”tax deadline

Zvilna v. Canada: Director’s Liability for Unpaid Taxes: A Canadian Tax Lawyer’s Note of Caution to Directors

Background on Directors Liability for Taxes: The Tax Court of Canada has recently decided a case regarding director’s liability for unremitted GST/HST. Generally, a director of a corporation can be held personally liable to CRA for various corporate liabilities such as unremitted GST and HST, as well as unremitted...

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