Table of Contents Overview: What Does Section 87 of the Indian Act Actually Say?……………………………………………. 3 Who Can Claim the Section 87 Exemption?…………………………………………………………………………. 4 Key Issues and Findings: Why Living on a Reserve Does Not Make All Income Tax-Free……………….. 5 The Connecting Factors Test…………………………………………………………………………………………………………………………….. 5 CRA’s Current Employment Income Guidelines……………………………………………………………………………………………….....
Table of Contents Overview: When Are a Subsidiary’s Losses Converted on a Wind-Up? Background: Why the Order of the Rules Changes the Answer What Happened in STC Steel? Key Issues and Findings: How Do Non-Capital Losses Transfer on a Corporate Wind-Up? What Are the Functional-Currency Rules Under Section 261?...
(National Revenue) v. Zeifmans LLP, 2026 FCA 147 Overview: CRA Requirements for Information, Unnamed Persons, and the Zeifmans Compliance Order If the CRA has served you or your accounting firm with a CRA requirement for information, and you are wondering whether you can refuse it, delay it, or fight...
Identity Theft, Human Trafficking, and CRA Benefit Overpayments: What Survivors Need to Know A survivor of human trafficking who has escaped and begun rebuilding often finds that the Canada Revenue Agency is still taking money from her every year. (In Canada, approximately 93% of police-reported human trafficking victims are...
Overview: Can You Claim Medical Tourism Expenses on Your Canadian Tax Return? Medical tourism has become a mainstream choice for Canadians facing long wait times or high out-of-pocket costs for dental implants, orthopedic procedures, fertility treatment, and other care. The good news is that fees paid to a properly...
Overview: The Offshore Investment Fund Property Rules in Plain Language If you hold units or shares of an offshore hedge fund, a foreign investment company or any other non-resident fund that reinvests its income instead of paying it out, the CRA may be able to tax you every year...
Overview: Accountant Privilege, CRA Compliance Orders, and the Income Tax Act The Federal Court’s June 12, 2026 decision in Minister of National Revenue v KPMG Canada LLP, T-139-26, is a significant ruling on the limits of privilege assertions by third-party tax advisors in the context of CRA audits. The...
Overview: Protecting Sensitive Business Records In Tax Court: Lessons From Canada v. CAE Inc., 2026 FCA 138 Litigating against the Canada Revenue Agency (CRA) often means handing over sensitive business records, some of which a company would never want a competitor, or the public, to see. The Federal Court...
Liu et al v The King and the Limits on Alternative Arguments in Tax Court Pleadings The Tax Court strikes the CRA’s attempt to plead a foreign accrual property income theory that was never part of the original tax reassessment, reaffirming firm limits on what subsection 152(9) permits. Liu...
Contents Overview: When a CRA Reassessment You Never Received Can Still Affect Your Objection Rights What Happened in Ducharme? The CRA’s $15.8 Million Penalty Reassessments and Motion to Quash Why Does the Mailing Date of a CRA Tax Assessment or Reassessment Matter? What Happens If the CRA Cannot Prove...