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  • Article

    A Guilty Plea To Tax Evasion? Beware The Civil Consequences

    It is almost always the case that criminal charges for tax evasion are accompanied by a civil assessment or reassessment of taxes.
    CanadaTax
    Thorsteinssons LLP
    Thorsteinssons LLP
  • Article

    A New Year, A Chance Of New Tax Rules For Professional Corporations

    In the 2015 federal budget, the Conservative government announced it would be reducing the small business tax rate over the next four years—which, at the time, was good news for many professional corporations.
    CanadaTax
    Grant Thornton
    Grant Thornton
  • Article

    Applying The Transfer Pricing Rules To Guarantees

At the time Canada was amending its transfer pricing rules, much concern – and some confusion – arose over the potential application of the rules to financial transactions. This was particularly the case where the tax consequences of applying those rules to financial transactions were already regulated under other provisions of the Canadian Income Tax Act.
CanadaTax
Blake, Cassels & Graydon LLP
Blake, Cassels & Graydon LLP
  • Article

    Assessments - Till Death Do Us Part?

    As we have previously written here and here, a taxpayer's debts can be imposed on their spouse or children through an assessment under section 160 of the Income Tax Act ("ITA").
    CanadaTax
    Millar Kreklewetz
    Millar Kreklewetz
  • Article

    B.C. Government Announces Foreign Buyers' Tax Exemption For Certain Limited Partnerships

    The provincial government recently amended the Property Transfer Tax Regulation, B.C. Reg. 74/88, to clarify how additional property transfer tax relating to foreign buyers applies...
    CanadaTax
    McCarthy Tétrault
    McCarthy Tétrault
  • Article

    Bonus Or Dividends? Questions For Business Owners In The Age Of New Income Splitting Rules

    As we approach the end of the year, owners of private companies often ask, "If I need to take money out of my corporation, should I pay myself a bonus or a dividend?"
    CanadaTax
    Crowe Soberman LLP
    Crowe Soberman LLP
  • Article

    Budget 2013: Further Restrictions On Loss Trading

    The Income Tax Act (Canada) (the "Tax Act") contains rules (the "loss trading rules") limiting the ability of a corporation to utilize losses and other tax pools that have arisen or were acquired prior to the acquisition of control of the corporation by an unrelated person.
    CanadaTax
    McMillan LLP
    McMillan LLP
  • Article

    Budget 2016: Taxation Of Emissions Trading Activities Clarified

    In several jurisdictions, regulated emitters are required by law to deliver "emissions allowances" to the government.
    CanadaTax
    McMillan LLP
    McMillan LLP
  • Article

    Budget 2019: The Art Of Political Distraction

    Time will tell if Budget 2019 saves the Liberal Government in the fall of 2019.
    CanadaTax
    Wildeboer Dellelce LLP
    Wildeboer Dellelce LLP
  • Article

    Budget 2022 Bill Receives Royal Assent

    On June 23, 2022, Bill C-19, Budget Implementation Act, 2022, No. 1 received Royal Assent (Bill C-19). Bill C-19 implements certain tax measures announced in Budget 2021 and Budget 2022...
    CanadaTax
    Cassels
    Cassels
  • Article

    Can The CRA Take My Home?

    When confronted with outstanding tax liability, individuals naturally harbor concern regarding the potential consequences and measures the Canada Revenue Agency ("CRA")...
    CanadaTax
    Rosen & Associates
    Rosen & Associates
  • Article

    Canada Revenue Agency Releases New Form T1135 To Report Foreign Property

    On Dec. 9, 2015, the Canada Revenue Agency (CRA) released a new version of prescribed Form T1135 for taxpayers who own specified foreign property.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    Case Comment – MNR v Roofmart Ontario Inc. ("Roofmart")

    The CRA has general powers to require persons to provide information related to a tax audit however these general powers are limited, such that, the CRA cannot require persons to provide third party documents without judicial authorization.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Changes To Employee Stock Option Deduction Calculation

    In the 2024 Federal Budget, the Department of Finance announced that capital gains realized by individuals on or after June 25, 2024 in excess of an annual $250,000 threshold will be subject to a two-thirds inclusion rate ...
    CanadaTax
    Miller Thomson
    Miller Thomson
  • Article

    Changes To The Taxation Of Restrictive Covenants

    These legislative changes are retroactive to October 7, 2003.
    CanadaTax
    Collins Barrow National Incorporated
    Collins Barrow National Incorporated
  • Article

    Claiming Privilege Against CCRA—The Good News And The Bad News From Recent Cases

    In the course of an audit, the Canada Customs and Revenue Agency (CCRA) has the ability to require a taxpayer’s accountants and lawyers to provide documents and information in their possession. CCRA’s rights are not unrestricted and, in several recent cases, the scope of the protection of documents from disclosure on the grounds of solicitor-client privilege has been tested
    CanadaTax
    Blake, Cassels & Graydon LLP
    Blake, Cassels & Graydon LLP
  • Article

    Client Update: Taxation Of Trusts, Estates And Charitable Donation Rules Changing January 1, 2016

    This client update is an attempt to summarize the more significant aspects of the rules.
    CanadaTax
    Stewart McKelvey
    Stewart McKelvey
  • Article

    COVID-19 Relief For Resource Companies: Resource Issuers May Rely On Proposed Extensions

    Resource companies that have issued flow-through shares shortly before or during the global COVID-19 pandemic may have faced difficulties, including the shutdown of mines, incurring eligible resource expenses ...
    CanadaTax
    Miller Thomson
    Miller Thomson
  • Article

    CRA's $1 Billion Real Estate Nut: Tough To Crack

    The Canada Revenue Agency recently published a news release, in which it identifies over $1 billion in unpaid taxes in the BC and Ontario real estate sectors since 2015.
    CanadaTax
    KPK Law LLP
    KPK Law LLP
  • Article

    CRA Announces Proposed Changes To The Voluntary Disclosure Program

    In June 2017, the Canada Revenue Agency released its proposed changes to the voluntary disclosure program relating to income tax, excise tax, GST/HST and excise duties (Taxes).
    CanadaTax
    Cassels
    Cassels
  • Showing 941–960 of 5654 results

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