Blockchain or Cryptocurrency Fraud – Cryptocurrency Fraudulent Investment Schemes The advent of blockchain technology and cryptocurrencies has resulted in sudden fortunes for more than a few individuals. At the same time, the technology and economics of the cryptocurrency space are confusing and not well understood by the general public....
Introduction to the Relevant Law on TFSA Over-Contribution and Non-Resident Contribution Before discussing the case of Ifi v. Canada (Attorney General), 2020 FC 1150, an introduction to the underlying law is necessary to provide context. Tax-Free Savings Accounts (TFSAs) are popular savings and investment tools for Canadians. A taxpayer...
Introduction: Cryptocurrency-Trading Businesses in Canada Canadian cryptocurrency-trading businesses face unique challenges. The mostly unregulated market brings higher risk of fraud and cyber-crime. The volatile markets may bleed profits. And some cryptocurrency traders don’t even realize that they’re carrying on a business, misreporting their profits as capital gains. This article...
Introduction – Indirect Tax Audit Methods Canada’s income tax system is designed around every taxpayer, individual, corporation or trust, filing an annual return which reports all of the income that taxpayer earned during the year. Similarly, GST/HST is administered by requiring suppliers of goods and services to regularly file...
Money transferred from a corporation to its shareholder was reassessed as shareholder benefits This case was a split decision with the taxpayer’s Canadian tax lawyer winning the argument against gross negligence penalties but losing with respect to statute barred years. Mr. Deyab and his spouse carried out engineering consulting...
Introduction – Taxation of Testamentary Trusts and Estates A testamentary trust is one that is created as a result of the death of an individual. Under the Canadian income tax system, once an individual dies, all of that individual’s assets are deemed to have been disposed and then reacquired...
The Canada Revenue Agency’s low prescribed rate opens up income splitting opportunities – A Canadian tax lawyer’s tax guidance The Canada Revenue Agency announced 1 percent prescribed rate starting July 1, 2020 The prescribed rate set by the Canada Revenue Agency (CRA) has been 1 percent since July 1,...
Introduction – Tax Search Warrants Canada’s federal Income Tax Act includes provisions that grant the Canada Revenue Agency (the “CRA”) a wide range of powers for administering and enforcing the Act. For instance, section 231.1 grants the CRA the power to tax audit and inspect the books and records...
Introduction – Tax Search Warrants Canada’s federal Income Tax Act includes provisions that grant the Canada Revenue Agency (the “CRA”) a wide range of powers for administering and enforcing the Act. For instance, section 231.1 grants the CRA the power to tax audit and inspect the books and records...
Introduction – Business Tax Audit Business tax audits are a keyway by which the Canada Revenue Agency (CRA) ensures that a business has fulfilled its tax obligations with respect to income tax, payroll deductions, benefits, remittances, and GST/HST, pursuant to the Income Tax Act and the Excise Tax Act....