Loss carryovers are an important tool that taxpayers can utilize to reduce their taxable income. When taxpayer incurs a loss, they can use the...
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In 2009, the Tax-Free Savings Account (“TFSA”) program was introduced by the federal government of Canada as a means to allow Canadian families and...
Overview: Unique Tax Considerations for Shareholder-Employees of a Corporation It is not uncommon within incorporated family businesses or other closely-held private corporations for the...
Introduction: Rectification & Its Tax Consequences Rectification is an equitable remedy. It allows parties to correct drafting errors that would otherwise render a legal...
Big box store was ordered by the Federal Court to turn over its client lists to the CRA In November 2022, the Federal Court...
Introduction: The General Anti-Avoidance Rule & Documentary Discovery during Tax Litigation Section 245 of Canada’s Income Tax Act contains the general anti-avoidance rule (also...
Introduction – What are Statute-Barred Tax Years? The Canadian tax system is based on the principles of self-assessment, which requires that Canadian taxpayers perform...
A gift is generally defined as a voluntary and gratuitous transfer of property, without any consideration given in exchange. A personal gift made in...
Introduction – Digital Payment Services and Financial Reporting Obligations Digital payment services like those offered by PayPal, which are used to facilitate money transfers...
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 foreign property” with a cost...
Penalties Canada’s tax statutes contain various penalties that seek to curb non-compliance. A gross-negligence penalty aims to punish a taxpayer whose conduct “involves a...
Background: What is an NFT? A non-fungible token (NFT) is a unique digital asset that is built on top of the blockchain system. It...
Background on Directors Liability for Taxes: The Tax Court of Canada has recently decided a case regarding director’s liability for unremitted GST/HST. Generally, a...
Change in Use of Principal Residence, Principal Residence Exemption and Subsection 45(2) Election When there is a change in use of your principal residence,...
Introduction – Canadian Taxpayers Must Pay Departure Tax When Leaving Canada There are two types of individuals who must pay tax in Canada –...
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...
Introduction – Cryptocurrency and NFTs should be disclosed as matrimonial property A divorce will result in many financial changes and one of the major...
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...
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...
What is the T1135? The T1135 is a reporting form where Canadian resident taxpayers report to the Canada Revenue Agency any specified foreign property...
Tax Court Settlement Process A taxpayer who proceeds to Tax Court to resolve an ongoing tax dispute will want to consider settling the dispute...
Filing Tax Returns -Starting Point in the Administration of Income Tax Law in Canada Generally speaking, the starting point regarding the administration of income...
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...
Introduction – Cryptocurrency Transactions and Taxation Cryptocurrency is a popular means of conducting transactions online. Widespread cryptocurrency tokens such as Bitcoin, Ethereum, Litecoin, Dash,...
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...
TFSA Background – TFSA Anti-Avoidance Rules: Prohibited and Non-Qualified Investments Tax Free Savings Account (TFSA) plans are a tax efficient method of investment for...
What are Net Worth Tax Audits? A net worth audit is an indirect tax audit technique used by the Canada Revenue Agency or CRA...
Introduction: The Starting Point of the Taxation of Employment Income Every person resident in Canada must pay income tax on the taxable income for...
Overview – Emigrating from Canada with Stock Options Most forms of remuneration for employment are taxed as income in the year they are received...
Introduction: Enforcement of the Canadian Tax System As the Canadian tax system is based upon taxpayers self-assessing and self-reporting their income, to protect the...
Introduction – What are Non-Fungible Tokens (NFTs)? While cryptocurrencies like Bitcoin and Ether have been intensely popular for some time, NFTs are a relatively...
Read more about a Canadian tax lawyer's perspective on how the John Wall case affected the application of principal residence exception to home developers.
Introduction – The Canada Emergency Wage Subsidy Many Canadian businesses have been impacted by the ongoing COVID-19 pandemic. While many businesses are experiencing financial...
RRSP and TFSA Over-Contribution Tax Each year individuals have a certain amount they can contribute to their Registered Retirement Savings Plan (“RRSP”) and Tax...
Introduction: The CRA’s Voluntary Disclosures Program The Voluntary Disclosures Program (VDP), also known as tax amnesty, is a program offered by the Canada Revenue...
Introduction: Why do private corporations receive Refundable Dividends? Canada’s Income Tax Act was originally drafted with three main principles in mind: equity, simplicity, and...
Cryptocurrency Reporting Requirements: OECD to Release Cryptocurrency Reporting Framework in 2021 The Organisation for Economic Co-operation and Development (“OECD”) is due to release a...
Merrill v R – tax guidance from an experienced Canadian tax lawyer with respect to failure to file tax returns In 2019, the Canada...
Introduction – Corporate Tax Arrangements of ViacomCBS ViacomCBS is a multinational media corporation that owns the rights to multiple blockbuster franchises including Teenage Mutant...
T1134 Form – Introduction by Toronto Tax Lawyer The Canadian Income Tax Act levies income tax on the worldwide income of resident Canadians. Multinational business...
Introduction – What are Taxable Benefits Under Paragraph 6(1)(a) of the Income Tax Act, a taxable benefit is any advantage or benefit given to...
Introduction: What is “Rescission”? Rescission allows for a transaction to be retroactively cancelled, annulled, or set aside in circumstances where there has been a...
Introduction – Employee Stock Options Certain corporations offer stock options to their employees as a form of compensation. Employee stock options give employees the...
Introduction: Cryptocurrency-Trading Businesses in Canada Canadian cryptocurrency-trading businesses face unique challenges. The mostly unregulated cryptocurrency, non-fungible token (NFT), and blockchain markets brings higher risk...
Overview – T1135 Reporting Requirement: Exception for Interests in Non-Resident Trusts Not Acquired for Consideration Canadian who own specified foreign property with a combined...
Requirements for Part XIII Withholding Tax on Canadian Interest to Non-Residents – A Toronto Tax Lawyer Guide Introduction – What is Withholding Tax on...
What is Canadian Departure Tax? When taxpayers emigrate from Canada, for tax purposes they are deemed to have disposed of their capital assets even...
Introduction – Repeated Failure to File Income Tax Penalty Under Canada’s income tax system, taxpayers are required to calculate, report and pay their taxes...
Introduction: The Canada Revenue Agency’s Overzealous Use of Gross-Negligence Penalties Gross-negligence penalties aim to punish taxpayers whose conduct “involves a high degree of negligence tantamount...
Introduction: Derivative Tax Liability under Section 160 of the Income Tax Act & Transfers to Trustees Section 160 of the Income Tax Act is...
Introduction – CRA’s Court Order against Coinsquare On September 18, 2020, the CRA filed a Federal Court application against Coinsquare in order to compell...
What is a Tax Notice of Objection? A tax Notice of Objection is a formal dispute filed with the Canada Revenue Agency wherein the...
Introduction – Tax Remission Order Canada’s tax laws contain provisions that are carefully crafted and precisely designed to provide taxpayers with various avenues to...
Introduction – Blockchain or Cryptocurrency Liquidity Mining and Yield Farming Blockchain or cryptocurrency liquidity mining (also called cryptocurrency yield farming) is an arrangement whereby...
Blockchain or Cryptocurrency Fraud – Cryptocurrency Fraudulent Investment Schemes The advent of blockchain technology and cryptocurrencies has resulted in sudden fortunes for more than...
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,...
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...
Introduction – Indirect Tax Audit Methods Canada’s income tax system is designed around every taxpayer, individual, corporation or trust, filing an annual return which...
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...
Introduction – Taxation of Testamentary Trusts and Estates A testamentary trust is one that is created as a result of the death of an...
The Canada Revenue Agency’s low prescribed rate opens up income splitting opportunities – A Canadian tax lawyer’s tax guidance The Canada Revenue Agency announced...
Introduction – Tax Search Warrants Canada’s federal Income Tax Act includes provisions that grant the Canada Revenue Agency (the “CRA”) a wide range of...
Introduction – Tax Search Warrants Canada’s federal Income Tax Act includes provisions that grant the Canada Revenue Agency (the “CRA”) a wide range of...
Introduction – Business Tax Audit Business tax audits are a keyway by which the Canada Revenue Agency (CRA) ensures that a business has fulfilled...
An employee housing loan refers to any loan that you can get from your employer to buy a home. This is quite convenient, considering...
If you are curious about using a shareholder loan and want to know the potential fallout that it could have for you in terms...
Winston Churchill is reputed to have said, “We contend that for a nation to try to tax itself into prosperity is like a man...
Tax planning is very difficult and stressful to handle on your own and it is not at all easy to achieve the tax planning...
Tax law is complex and it is unwise to proceed without proper guidance. The extensive powers granted by the Canadian Income Tax Act to...
Even before a tax debtor has time to react or engage a tax expert his bank accounts can be seized and money taken without...
Tackling tax problems is difficult enough and to add to that if you are dealing with CRA auditors or CRA tax collectors, professional representation...
Tax evasion is an offence under the Income Tax Act and the Excise Tax Act (for GST/HST) but notably it is not a criminal...
We are a specialized Canadian tax law firm with 30 years of experience and have seen it all, so our experience tells us that...
Any problem related to tax and tax audit is difficult and stressful to manage on your own .In the Canadian income tax system it...
Canada’s Tax Act gives sweeping powers to the Canada Revenue Agency and by extension its tax collection officers, to collect the tax debts of...