Loss carryovers are an important tool that taxpayers can utilize to reduce their taxable income. When taxpayer incurs a...
In 2009, the Tax-Free Savings Account (“TFSA”) program was introduced by the federal government of Canada as a means...
Overview: Unique Tax Considerations for Shareholder-Employees of a Corporation It is not uncommon within incorporated family businesses or other...
Introduction: Rectification & Its Tax Consequences Rectification is an equitable remedy. It allows parties to correct drafting errors that...
Big box store was ordered by the Federal Court to turn over its client lists to the CRA In...
Introduction: The General Anti-Avoidance Rule & Documentary Discovery during Tax Litigation Section 245 of Canada’s Income Tax Act contains...
Introduction – What are Statute-Barred Tax Years? The Canadian tax system is based on the principles of self-assessment, which...
A gift is generally defined as a voluntary and gratuitous transfer of property, without any consideration given in exchange....
Introduction – Digital Payment Services and Financial Reporting Obligations Digital payment services like those offered by PayPal, which are...
Introduction – T1135s and Beneficial Ownership The Canadian Income Tax Act requires that Canadian tax residents who own “specified...
Penalties Canada’s tax statutes contain various penalties that seek to curb non-compliance. A gross-negligence penalty aims to punish a...
Background: What is an NFT? A non-fungible token (NFT) is a unique digital asset that is built on top...
Background on Directors Liability for Taxes: The Tax Court of Canada has recently decided a case regarding director’s liability...
Change in Use of Principal Residence, Principal Residence Exemption and Subsection 45(2) Election When there is a change in...
Introduction – Canadian Taxpayers Must Pay Departure Tax When Leaving Canada There are two types of individuals who must...
Introduction to Third-Party Tax Liabilities under Section 160 and Section 325 Section 160 of the Income Tax Act and...
Introduction – Cryptocurrency and NFTs should be disclosed as matrimonial property A divorce will result in many financial changes...
What is the Voluntary Disclosure Program? The Canada Revenue Agency’s voluntary disclosure program allows taxpayers to come forward proactively...
Introduction: Net Worth Assessments Net worth assessments may be undertaken by the tax auditor when the Canada Revenue Agency...
What is the T1135? The T1135 is a reporting form where Canadian resident taxpayers report to the Canada Revenue...
Tax Court Settlement Process A taxpayer who proceeds to Tax Court to resolve an ongoing tax dispute will want...
Filing Tax Returns -Starting Point in the Administration of Income Tax Law in Canada Generally speaking, the starting point...
As a result of China’s recent crackdown on bitcoin mining, in July 2021, Black Rock Petroleum Company, a Nevada...
Introduction – Cryptocurrency Transactions and Taxation Cryptocurrency is a popular means of conducting transactions online. Widespread cryptocurrency tokens such...
RRSP Background – RRSP Anti-Avoidance Rules: Prohibited and Non-Qualified Investments Registered retirement savings plans (RRSPs) are a tax efficient...
TFSA Background – TFSA Anti-Avoidance Rules: Prohibited and Non-Qualified Investments Tax Free Savings Account (TFSA) plans are a tax...
What are Net Worth Tax Audits? A net worth audit is an indirect tax audit technique used by the...
Introduction: The Starting Point of the Taxation of Employment Income Every person resident in Canada must pay income tax...
Overview – Emigrating from Canada with Stock Options Most forms of remuneration for employment are taxed as income in...
Introduction: Enforcement of the Canadian Tax System As the Canadian tax system is based upon taxpayers self-assessing and self-reporting...
Introduction – What are Non-Fungible Tokens (NFTs)? While cryptocurrencies like Bitcoin and Ether have been intensely popular for some...
Read more about a Canadian tax lawyer's perspective on how the John Wall case affected the application of principal...
Introduction – The Canada Emergency Wage Subsidy Many Canadian businesses have been impacted by the ongoing COVID-19 pandemic. While...
RRSP and TFSA Over-Contribution Tax Each year individuals have a certain amount they can contribute to their Registered Retirement...
Introduction: The CRA’s Voluntary Disclosures Program The Voluntary Disclosures Program (VDP), also known as tax amnesty, is a program...
Introduction: Why do private corporations receive Refundable Dividends? Canada’s Income Tax Act was originally drafted with three main principles...
Cryptocurrency Reporting Requirements: OECD to Release Cryptocurrency Reporting Framework in 2021 The Organisation for Economic Co-operation and Development (“OECD”)...
Merrill v R – tax guidance from an experienced Canadian tax lawyer with respect to failure to file tax...
Introduction – Corporate Tax Arrangements of ViacomCBS ViacomCBS is a multinational media corporation that owns the rights to multiple...
T1134 Form – Introduction by Toronto Tax Lawyer The Canadian Income Tax Act levies income tax on the worldwide income...
Introduction – What are Taxable Benefits Under Paragraph 6(1)(a) of the Income Tax Act, a taxable benefit is any...
Introduction: What is “Rescission”? Rescission allows for a transaction to be retroactively cancelled, annulled, or set aside in circumstances...
Introduction – Employee Stock Options Certain corporations offer stock options to their employees as a form of compensation. Employee...
Introduction: Cryptocurrency-Trading Businesses in Canada Canadian cryptocurrency-trading businesses face unique challenges. The mostly unregulated cryptocurrency, non-fungible token (NFT), and...
Overview – T1135 Reporting Requirement: Exception for Interests in Non-Resident Trusts Not Acquired for Consideration Canadian who own specified...
Requirements for Part XIII Withholding Tax on Canadian Interest to Non-Residents – A Toronto Tax Lawyer Guide Introduction –...
What is Canadian Departure Tax? When taxpayers emigrate from Canada, for tax purposes they are deemed to have disposed...
Introduction – Repeated Failure to File Income Tax Penalty Under Canada’s income tax system, taxpayers are required to calculate,...
Introduction: The Canada Revenue Agency’s Overzealous Use of Gross-Negligence Penalties Gross-negligence penalties aim to punish taxpayers whose conduct “involves a...
Introduction: Derivative Tax Liability under Section 160 of the Income Tax Act & Transfers to Trustees Section 160 of...
Introduction – CRA’s Court Order against Coinsquare On September 18, 2020, the CRA filed a Federal Court application against...
What is a Tax Notice of Objection? A tax Notice of Objection is a formal dispute filed with the...
Introduction – Tax Remission Order Canada’s tax laws contain provisions that are carefully crafted and precisely designed to provide...
Introduction – Blockchain or Cryptocurrency Liquidity Mining and Yield Farming Blockchain or cryptocurrency liquidity mining (also called cryptocurrency yield...
Blockchain or Cryptocurrency Fraud – Cryptocurrency Fraudulent Investment Schemes The advent of blockchain technology and cryptocurrencies has resulted in...
Introduction to the Relevant Law on TFSA Over-Contribution and Non-Resident Contribution Before discussing the case of Ifi v. Canada...
Introduction: Cryptocurrency-Trading Businesses in Canada Canadian cryptocurrency-trading businesses face unique challenges. The mostly unregulated market brings higher risk of...
Introduction – Indirect Tax Audit Methods Canada’s income tax system is designed around every taxpayer, individual, corporation or trust,...
Money transferred from a corporation to its shareholder was reassessed as shareholder benefits This case was a split decision...
Introduction – Taxation of Testamentary Trusts and Estates A testamentary trust is one that is created as a result...
The Canada Revenue Agency’s low prescribed rate opens up income splitting opportunities – A Canadian tax lawyer’s tax guidance...
Introduction – Tax Search Warrants Canada’s federal Income Tax Act includes provisions that grant the Canada Revenue Agency (the...
Introduction – Tax Search Warrants Canada’s federal Income Tax Act includes provisions that grant the Canada Revenue Agency (the...
Introduction – Business Tax Audit Business tax audits are a keyway by which the Canada Revenue Agency (CRA) ensures...
An employee housing loan refers to any loan that you can get from your employer to buy a home....
If you are curious about using a shareholder loan and want to know the potential fallout that it could...
Winston Churchill is reputed to have said, “We contend that for a nation to try to tax itself into...
Tax planning is very difficult and stressful to handle on your own and it is not at all easy ...
Tax law is complex and it is unwise to proceed without proper guidance. The extensive powers granted by the...
Even before a tax debtor has time to react or engage a tax expert his bank accounts can be...
Tackling tax problems is difficult enough and to add to that if you are dealing with CRA auditors or...
Tax evasion is an offence under the Income Tax Act and the Excise Tax Act (for GST/HST) but notably...
We are a specialized Canadian tax law firm with 30 years of experience and have seen it all, so...
Any problem related to tax and tax audit is difficult and stressful to manage on your own .In the...
Canada’s Tax Act gives sweeping powers to the Canada Revenue Agency and by extension its tax collection officers, to...