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Many trustees do not follow the legalities surrounding family trusts in corporate transactions. On a share sale transaction, the trustees (often one or both of the patriarch or matriarch....

To date, the Canada Revenue Agency (CRA) has denied more than $5.5 billion in donation claims and reassessed over 167,000 taxpayers who participated in gifting tax shelter schemes.

The Canada Revenue Agency recently took the unusual and unconventional step of notifying the tax community that it has settled a matter relating to a hybrid financing arrangement involving

On December 15, 2008, the Fifth Protocol to the Canada - US Income Tax Convention (Treaty) came into force.

Cross-border couples face complex tax implications when a Canadian spouse names their U.S. citizen partner as beneficiary of a Tax-Free Savings Account (TFSA). While TFSAs offer tax advantages in Canada, the IRS treats income from these accounts differently for U.S. persons, creating unexpected reporting obligations and potential tax consequences that require careful estate planning coordination between both countries.

Many could be considered somewhere in between.

On July 27, 2020, as part of Canada's continued response to the COVID-19 pandemic, Bill C‑20 received Royal Assent and came into effect, enacting the Time Limits ...

Subparagraph 165(1)(a)(ii) of the Tax Act only requires, in essence, that a CRA notice of assessment be sent.

This paper provides analysis of one of the foundational elements of the Foreign Account Tax Compliance Act (FATCA) and various intergovernmental agreements (IGAs)...

On February 20, 2026, the Federal Court of Appeal ("FCA") released its decision in Canada v. DAC Investment Holdings Inc., 2026 FCA 35 ("DAC"), overturning the Tax Court of Canada's ("TCC")...

On August 20, federal officials announced that the Canada Emergency Response Benefit (CERB)

In the decision of Watts v. The King, 2023 TCC 11, the Tax Court of Canada reiterated, at paragraph 58, that "with or without an assessment, the liability for the tax debt exists.

The Canada Revenue Agency had an important win this week in its efforts to access information outside of Canada.

BMO carried on business through U.S. branches and was subject to both U.S. federal and New York City income taxes. After IRS audits for 1997–2001...

In a recent news story out of Millarville, Alberta, a woman who has been unable to sell her home has instead decided to give it away in a letter writing contest.

When an athlete signs with a US team, one of the most common questions I hear is: "How do I get a green card?"

Sub-sections 159 (1), 159 (2) and 159 (3) of the Income Tax Act (ITA) and their Quebec equivalents operate to impose personal liability for income tax