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  • Article

    Private Corporations – Giving Credit Where Credit Is Not Due.

    As confirmed in the Fall Economic Update (FEU), the Government of Canada has now retreated from some of the private corporation tax proposals set out in the July consultation paper.
    CanadaTax
    Crowe Soberman LLP
    Crowe Soberman LLP
  • Article

    Sale Of Property By Non-Residents: New Rules For Withholding Tax

    Commencing from the beginning of 2009 new Canadian tax rules came into effect in respect of the sale of property by non-residents.
    CanadaTax
    Gowling WLG
    Gowling WLG
  • Article

Tax Disputes Amidst COVID-19

In these times of uncertainty due to the pandemic, you may be wondering about the implications to your current audits and tax disputes with the Canada Revenue Agency ("CRA").
CanadaTax
Aird & Berlis LLP
Aird & Berlis LLP
  • Article

    Tax Guidance To Canada Revenue Agency's Extended Work-from-home Reimbursement To Home Office Equipment – A Canadian Tax Lawyer's Analysis

    In late October 2020, the CRA provided some good news at the Canadian Tax Foundation's annual roundtable session and one new policy specifically dealt with employers' reimbursement of computer and office equipment.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Tax Litigants May Amend Their Arguments During A Trial – A Toronto Tax Lawyer Analysis Of The Queen v Pomeroy Acquireco Ltd

    In the course of an appeal to the Tax Court of Canada by a Canadian taxpayer against the CRA, the Canadian tax litigation lawyers for both the taxpayer and the CRA may amend their pleadings under the Tax Court of Canada Rules (General Procedure).
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Taxation Of Switch Fund Shares

    General provisions in the ITA applicable to corporations and their shareholders provide that, in certain circumstances, an exchange of shares of a corporation by a taxpayer is deemed not to be...
    CanadaTax
    Gowling WLG
    Gowling WLG
  • Article

    Taxpayer Relief – T1135

    Canadian residents2 who own specified foreign property (SFP) that has a cost of over $100,000 during the year must complete form T1135, ...
    CanadaTax
    Borden Ladner Gervais LLP
    Borden Ladner Gervais LLP
  • Article

    The CRA Cannot Compel Oral Interviews During an Audit

    Finally, the FCA examined the legislative history of the provision.
    CanadaTax
    Davies Ward Phillips & Vineberg LLP
    Davies Ward Phillips & Vineberg LLP
  • Article

    The Hidden Costs Of Litigation: Lessons From Watts v The King

    It may be well-known that litigation can be an expensive venture, but the nuances of how costs can impact a case are often overlooked. The recent decision in Watts v The King, 2024 TCC 100...
    CanadaTax
    Rosen & Associates
    Rosen & Associates
  • Article

    The New Trust Loss Restriction Rules And Investment Funds

    In the 2013 federal budget, the Canadian government announced its intention to extend the tax loss restriction rules to trusts.
    CanadaTax
    Borden Ladner Gervais LLP
    Borden Ladner Gervais LLP
  • Article

    The Plan To Reopen The Tax Court And The New Fast Track Settlement Conference System

    On June 4, 2020, in a special virtual meeting held with the Tax Court of Canada Bench & Bar Liaison Committee, the Tax Court of Canada outlined its tentative plan to resume operations...
    CanadaTax
    Aird & Berlis LLP
    Aird & Berlis LLP
  • Article

    The Trump Bump? Why More US Expats Are Looking To Renounce Their Citizenship

    In the wake of Donald Trump's 2024 election victory, many US expats are taking a hard look at their American citizenship—and deciding that renunciation may be their best option.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    Understanding The CRA Notice Of Assessment

    Most of us have received our Notice of Assessment from the CRA for our 2020 tax returns. Mostly it's petty much as you expected – a refund or no balance owing.
    CanadaTax
    Minden Gross LLP
    Minden Gross LLP
  • Article

    What Happens To My Social Security Payments?' And Some Common Myths About Life After Renouncing Your US Citizenship

    One of the most popular questions I get during my renunciation webinars and over the 4,000 files I've handled is, "Will I lose my Social Security after I renounce my US citizenship?"
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    What Is So Civil About Penalties, Anyway?

    When it comes to tax law, governments have two main arrows in their quiver.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    When A Tax Court Appeal Becomes Cost, Not Opportunity

    The appeal failed because the parties continued after the win path had closed. The hearing created no real opportunity or upside.
    CanadaTax
    Counter Tax Litigators LLP
    Counter Tax Litigators LLP
  • Article

    When Is A Financial Institution Not A Financial Institution: CRA Announces New Administrative Positions On FATCA/CRS Compliance

    Today, the Canada Revenue Agency (CRA) published its new administrative positions on the compliance obligations of financial institutions under Part XVIII (FATCA) and Part XIX (CRS) of the Income Tax Act (Canada).
    CanadaTax
    Borden Ladner Gervais LLP
    Borden Ladner Gervais LLP
  • Article

    Will He Stay Or Will He Go? The Kawhi Leonard Saga

    Four bounces off the rim… and in! A thundering slam dunk over the presumptive NBA MVP. Nailing two free throws in the final 0.9 seconds—sealing the first ever NBA Championship for the Toronto Raptors.
    CanadaTax
    Crowe Soberman LLP
    Crowe Soberman LLP
  • Article

    Wilson: SCC Overhauls Standard Of Review?

    Tax professionals who advise clients on judicial review of the CRA's discretionary decisions should monitor developments in the standard of review of the Supreme Court of Canada's decision in Wilson v Atomic Energy of Canada Ltd.
    CanadaTax
    Dentons Canada LLP
    Dentons Canada LLP
  • Article

    Privacy: What's Left?

    A seismic change in the international private wealth arena is under way.
    GlobalTax
    Stikeman Elliott LLP
    Stikeman Elliott LLP
  • Showing 941–960 of 3220 results

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