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  • Article

    Private Corporations - Fall Update

    A few months ago, I wrote about the cruel summer I was having trying to understand, explain and rationalize the new tax rules about private companies released on July 18.
    CanadaTax
    Minden Gross LLP
    Minden Gross LLP
  • Article

    Restrictions On Non-Resident Ownership

    For a number of reasons, income trusts have featured prominently in the business media in the last few months. One issue that has garnered its share of headlines concerns the restrictions on ownership of income trusts by non-residents that often apply under Canadian income tax law
    CanadaTax
    Blake, Cassels & Graydon LLP
    Blake, Cassels & Graydon LLP
  • Article

Statute Of Limitations In Tax Audits

Tax auditors generally operate within a four-year limitation period when conducting audits, but this protection is not absolute. Understanding when the Canada Revenue Agency and provincial tax authorities can reassess beyond this timeframe—particularly in cases involving misrepresentation, neglect, or fraud—is critical for taxpayers who assume older years are permanently closed.
CanadaTax
Millar Kreklewetz
Millar Kreklewetz
  • Article

    Strengthening The Intergenerational Business Transfer Framework

    The Intergenerational Business Transfer ("IBT") regulations came into effect on June 29, 2021, through Bill C-208. Before this, when parents transferred shares of their...
    CanadaTax
    Rosen & Associates
    Rosen & Associates
  • Article

    Tax Objections: What Happens Next?

    Canadian tax appeals processes can involve lengthy wait times and unclear communication from authorities, but when action is required, deadlines become suddenly urgent.
    CanadaTax
    Millar Kreklewetz
    Millar Kreklewetz
  • Article

    The New Thin-Cap: Lenders Take Heed!

    Canada's thin-capitalization rule has changed.
    CanadaTax
    Dale & Lessmann LLP
    Dale & Lessmann LLP
  • Article

    The OECD’s Base Erosion And Profit Shifting ("BEPS") Project

    For tax geeks like me, the OECD’s BEPS project has been fascinating to watch and participate in the debate.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    The TaxLetter: It's That Time, Year End Tax Planning

    The holiday season is officially here – and with it comes the desire give, give, give. So with that holiday spirit in mind, my gift to you is some last- minute, tax-planning tips to cut your tax bill for 2017.
    CanadaTax
    Minden Gross LLP
    Minden Gross LLP
  • Article

    The TaxLetter: New Tax Order

    October 2015 ushered in a new era of federal politics with the election of Justin Trudeau and his Liberal Party.
    CanadaTax
    Minden Gross LLP
    Minden Gross LLP
  • Article

    The TaxLetter: Taxpayer Beware

    The Liberal government's Federal Budget was released on March 22, 2016, with the theme of "growing the middle class".
    CanadaTax
    Minden Gross LLP
    Minden Gross LLP
  • Article

    The Top 6 Canadian Private Client Tax Predictions For 2019

    The next calendar year will likely see many tax changes in Canada and the United States.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    Transfer Pricing Rules In Canada

    On March 26, 2026, Canada's new transfer pricing rules received royal assent and will have a significant impact on multi-national enterprises (MNEs) in life sciences industries.
    CanadaTax
    Bennett Jones LLP
    Bennett Jones LLP
  • Article

    US Shareholder Of A Canco After 2017 Tax Reform

    Public Law no. 115-97 (2017 tax act)—the Tax Cuts and Jobs Act, signed December 22, 2017—significantly changed the Code and negatively affects a US person in Canada holding shares in a closely held corporation.
    CanadaTax
    KPK Law LLP
    KPK Law LLP
  • Article

    Are You Required To File A GST111 – Financial Institution Annual Information Return??

    In addition to such penalties, effective May 2017 the CRA will apply a non-compliance hold to reporting institutions that have outstanding GST111 returns.
    CanadaTax
    Collins Barrow National Incorporated
    Collins Barrow National Incorporated
  • Article

    Federal Budget 2016 - Introduction

    Le 22 mars 2016, le ministre des Finances, Monsieur Bill Morneau, a déposé le très attendu budget fédéral 2016 (le « budget »), soit le premier budget du gouvernement libéral, intitulé « Assurer la croissance de la classe moyenne ».
    CanadaTax
    Miller Thomson
    Miller Thomson
  • Article

    How To Use BVI Or Other Offshore Non-CCPCs To Save Tax On Investment Income – Guidance From A Canadian Tax Lawyer

    Most Canadian small businesses operate as CCPCs (Canadian controlled private corporations) which are entitled to many tax advantages such as a lower tax rate for active business income up to $500,000 annually.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    "Moodys 2.0″ - Exciting Changes!

    In Canada, the tax advisory profession is dominated by the accounting and legal professions. Much of what the two professions do is the same, however, there are also distinct differences.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    Top Ten CRA Audit Flags

    Taxpayers often ask why the CRA commenced an audit or whether taking a particular step might target them for a future audit.
    CanadaTax
    Gowling WLG
    Gowling WLG
  • Article

    2015 Federal Budget: Tax Highlights

    As has been widely predicted, today's federal budget (Budget 2015) delivered a handful of tax "goodies" in the lead-up to the coming election.
    CanadaTax
    Davies Ward Phillips & Vineberg LLP
    Davies Ward Phillips & Vineberg LLP
  • Article

    Canadian Branch Profits Tax – Challenging The Denial Of Treaty-Benefits For US LLCS

    The Canada Revenue Agency continues to deny the benefits of the reduced "branch profits" tax rate.
    CanadaTax
    McMillan LLP
    McMillan LLP
  • Showing 741–760 of 1610 results

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