Background: What is an NFT? A non-fungible token (NFT) is a unique digital asset that is built on top of the blockchain system. It is non-fungible in the sense that it is unique in nature: there is only one unique, original NFT. Cryptocurrencies (such as Bitcoin or Ethereum) or...
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...
Change in Use of Principal Residence, Principal Residence Exemption and Subsection 45(2) Election When there is a change in use of your principal residence, a deemed disposition occurs under subsection 45(1) of the Income Tax Act. The Canadian Tax Act states that a taxpayer will be deemed to have...
Introduction – Canadian Taxpayers Must Pay Departure Tax When Leaving Canada There are two types of individuals who must pay tax in Canada – Canadian residents and non-residents. Subject to various tax treaties and domestic tax rules, Canadian residents pay tax in Canada on their worldwide income while non-residents...
Introduction to Third-Party Tax Liabilities under Section 160 and Section 325 Section 160 of the Income Tax Act and Section 325 of the Excise Tax Act are derivative tax liability provisions. This means they empower the Canada Revenue Agency to pursue other people, third parties, for the unpaid income...
Introduction – Cryptocurrency and NFTs should be disclosed as matrimonial property A divorce will result in many financial changes and one of the major issues for divorcing couples is division of matrimonial property. As cryptocurrency and NFT investments continue to grow, a rising issue is whether they should be...
What is the Voluntary Disclosure Program? The Canada Revenue Agency’s voluntary disclosure program allows taxpayers to come forward proactively to correct prior errors or omissions with their taxes. Our experienced Canadian tax lawyers can identify whether the voluntary disclosure program would be beneficial and applicable for you. To incentivize...
Introduction: Net Worth Assessments Net worth assessments may be undertaken by the tax auditor when the Canada Revenue Agency (CRA) considers a taxpayer’s return to be inaccurate or when the taxpayer has not kept adequate records of the taxpayer’s income for one or more years. Subsection 152(7) of the...
What is the T1135? The T1135 is a reporting form where Canadian resident taxpayers report to the Canada Revenue Agency any specified foreign property they own if the specified foreign property has a cumulative adjusted cost base of $100,000 CAD or more. The T1135 does not create an obligation...
Tax Court Settlement Process A taxpayer who proceeds to Tax Court to resolve an ongoing tax dispute will want to consider settling the dispute prior to hearing. A settlement occurs where the taxpayer and Canada Revenue Agency agree to a particular outcome for the ongoing dispute without the involvement...