Introduction: Rectification & Its Tax Consequences Rectification is an equitable remedy. It allows parties to correct drafting errors that...
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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...
