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...
Introduction – Blockchain or Cryptocurrency Liquidity Mining and Yield Farming Blockchain or cryptocurrency liquidity mining (also called cryptocurrency yield farming) is an arrangement whereby you lend cryptocurrency to a start-up cryptocurrency platform seeking to raise capital. In return, the cryptocurrency platform usually gives you units or tokens of the...
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...