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...
Decoding Article XIV(6): Can Canadians Really Reclaim Departure Tax Under the Canada–Barbados Treaty? Opportunities for tax planning are virtually limitless. Provided your strategy aligns with both the wording and purpose of applicable Canadian tax legislation (in order to avoid a GAAR attack), it will likely withstand any challenges. Tax...
On Aug 15, 2025, the Canadian Government, through its Ministry of Finance and National Revenue, released for public consultation draft proposals for legislation in order to implement some previously announced tax measures and changes. These tax changes are numerous; however, this article will discuss some notable ones. The notable...
An Overview of the Canada Revenue Agency’s Administrative and Enforcement Powers The Canada Revenue Agency (CRA) possesses a wide range of administrative and enforcement powers in carrying out its mandate as the nation’s tax authority. These powers are extensive and complex, making the guidance of an experienced tax lawyer...
Dividend Tax Planning in Canadian Private Corporations For Canadian entrepreneurs and owner-managers, extracting value from a corporation is a central issue in Canadian corporate dividends and dividend tax planning. The decision to receive Canadian corporate dividends is not merely about cash flow. It directly affects overall tax efficiency, compliance...
In a November 13, 2025, decision, Baxter I.C.I. Corp. v. Attorney General of Canada, 2025 FC 1816, the Federal Court dismissed an application for judicial review, upholding a Canada Revenue Agency (CRA) decision that refused to waive or cancel penalties and interest for the applicant corporation. The case reinforces...