Overview — Canadian Students Cannot Pay for Multiple Years of Foreign Tuition, Then Claim Overpayments on Current-Year Taxes In Ojaide v. The King, 2025 TCC 180, the Tax Court of Canada addressed a specific but practical issue: whether a taxpayer can inflate a tuition tax credit for a taxation...
The Canada Revenue Agency’s drive to recover outstanding amounts from CRA COVID-19 benefit programs has now identified more than $10 billion in repayments due, marking a significant chapter in Canada’s fiscal response to the pandemic. This development carries direct relevance for Canadian taxpayers, encompassing professionals, entrepreneurs, investors, and accountants...
A salary deferral arrangement is an anti-avoidance rule in Canadian tax law, designed to prevent employees from deferring tax on income that has already been earned. The rules governing SDAs are complex and have significant implications for both employers and employees who wish to structure compensation in a tax-efficient...
When a loved one dies, taxes can impose a substantial and often unexpected burden on their estate. In Canada, the deemed disposition rules that apply at death frequently give rise to significant capital gains, and in certain circumstances, the same underlying value can be taxed more than once. Subsection...
Employee ownership trusts are increasingly recognized as a sophisticated and corporate tax planning option for Canadian private corporations. Recent federal legislative refinements have materially strengthened the employee ownership trust framework, improving certainty, flexibility, and long-term viability for business owners seeking an alternative to third-party sales or intergenerational transfers. For...
Overview of Critical Illness Insurance Tax Shelters and CRA Warnings for Canadian Entrepreneurs, Professionals, Investors, Accountants, and Crypto Investors In today’s complex Canadian tax environment, business owners and investors are increasingly encountering promotions for critical illness insurance tax shelters as a means to optimize corporate finances. These arrangements, which...
Tax Audits Versus Criminal Investigations As an experienced Canadian tax lawyer specializing in tax audits and tax investigations, I often advise clients on the critical distinctions between tax audits and criminal investigations under Canadian tax legislation, whether conducted by the Canada Revenue Agency (CRA) or Revenu Québec. The recent...
Court jurisdiction in Canadian tax disputes remains a persistent challenge for taxpayers who face assessments involving both federal and provincial income tax. The distinction becomes especially significant when the CRA assesses an individual’s provincial tax obligations based on the agency’s view of the taxpayer’s province of residence. The recent...
Taxation of Illegal Income: What Canadian Taxpayers Need to Know For obvious reasons, there is a tendency to conceal income derived from illegal activities from government authorities. However, there is no “pass” for failing to pay taxes owed to the Canada Revenue Agency (CRA) on such income. Taxpayers who...
In November 2022, the Canada Revenue Agency (CRA) addressed questions concerning the Canadian income tax implications of transferring the commuted value of benefits from a UK defined-benefit pension plan (“UK DB Plan”) to a self-invested personal pension (“UK SIPP”) by a Canadian tax resident. Specifically, the inquiry focused on...