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Transactions entered into between a Canadian taxpayer or partnership and a non-arm’s length non-resident are generally subject to the transfer pricing rules contained in section 247 of the <I>Income Tax Act</I>.

Crowdfunding is defined by Wikipedia as "the practice of funding a project or venture by raising many small amounts of money from a large number of people, typically via the Internet."

In CRA Technical Interpretation 2016-0647621E5, June 3, 2016, "Part IV Income Tax - Dividend Paid to a Corporate Trust Beneficiary", the CRA held that Part IV tax would apply on an allocation of dividends...

Effective January 1, 2017, the kinds of trusts that can claim the Principal Residence Exemption (PRE) will be limited.

The federal government has released much anticipated draft legislation proposing changes to the rules relating to the taxation of stock options.

The Government of Canada is taking immediate, significant and decisive action to help all Canadians who are dealing with financial hardship as a result of the Covid-19 outbreak.

This annual publication is produced by the National Tax Group of Fraser Milner Casgrain LLP (FMC), together with CCH.

On June 6, 2011, Finance Minister Jim Flaherty unveiled his first majority budget in the House of Commons.

The Budget contained a change of significance for some professionals including lawyers. The Budget proposes to pull back a long standing deferral that has existed with respect to work in progress.

On March 30, 2017, the Federal Court of Appeal (FCA) released its decision in BP Canada Energy Company v. MNR (2017 FCA 61), dealing with whether the Minister of National Revenue...

The Federal Court of Appeal (FCA) recently issued a pivotal ruling in Glencore Canada Corporation v R, sparking widespread discussion within the tax and industry sectors.

On May 19, 2020, the federal government released draft legislation, the Time Limits and Other Periods Act (COVID-19) (the "Time Limits Act".)

On November 11, 2012, the Government of the Hong Kong Special Administrative Region of the People's Republic of China and the Government of Canada signed a comprehensive income tax treaty.

On October 3, 2016, the Department of Finance released a Notice of Ways and Means Motion proposing changes to the principal residence rules.

The new B.C. Caregiver Credit is effective for 2018 and replaces the Infirm Dependent Tax Credit and the Caregiver Credit.

The IRS has announced a new amnesty program for U.S. persons with undisclosed foreign accounts or entities. U.S. persons with foreign accounts are required to report the existence of the accounts annually on Form TD F 90-22.1.

Individual shareholders who wish to withdraw funds from a corporation can face some tax challenges that are sometimes difficult to overcome.