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...
T1135s, Beneficial Ownership of Property, and Chan v The Queen: A Canadian Tax Lawyer’s Case Comment
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...