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...
Filing Tax Returns -Starting Point in the Administration of Income Tax Law in Canada Generally speaking, the starting point regarding the administration of income tax law in Canada is subsection 150(1), which states that a taxpayer must prepare and file an income tax return for each tax year without...
As a result of China’s recent crackdown on bitcoin mining, in July 2021, Black Rock Petroleum Company, a Nevada corporation, announced that it entered into an agreement with Optimum Mining Host Limited Liability Co. to relocate up to one million Bitcoin miners from China to Alberta, Canada. They agreed...
Introduction – Cryptocurrency Transactions and Taxation Cryptocurrency is a popular means of conducting transactions online. Widespread cryptocurrency tokens such as Bitcoin, Ethereum, Litecoin, Dash, and Stellar have become acceptable payment currencies for some e-commerce merchants across the world. For Canadian businesses that are looking to accept cryptocurrencies for payments...
RRSP Background – RRSP Anti-Avoidance Rules: Prohibited and Non-Qualified Investments Registered retirement savings plans (RRSPs) are a tax efficient method of investment for individuals created by the government to encourage Canadians to save for retirement. The basic structure of an RRSP is that a financial institution (the issuer) holds...