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By Sunita Doobay, B.A., LL.B., LL.M. (NYU), TEP
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.
By Vern Krishna
Please see Vern Krishna's latest article for the Taxnet Pro: Tax Disputes & Resolution Centre titled, "The Three Steps of GAAR" where he discusses the general anti-avoidance rule as a statutory commercial...
By David Piccolo
Please see David Piccolo's latest article for the September issue of the Tax Advocate titled, "A Review of Rectification in a Post-Fairmont World," ...
By Sunita Doobay, B.A., LL.B., LL.M. (NYU), TEP
Please see Sunita Doobay's latest article for the Canadian Tax Foundation's newsletter Canadian Tax Highlights which covers the U.S. Treasury Department and IRS Notice 2018-29, which makes three exceptions to the withholding requirement
By Sunita Doobay, B.A., LL.B., LL.M. (NYU), TEP
IRC section 267A, added December 2017, denies a deduction to a US-situated payer of interest or a royalty to a related non-US hybrid party or as part of a hybrid transaction.
By TaxChambers LLP
The ruling reflects that deemed trust rules are "quite strict," and should be a warning to lenders to investigate a borrower's existing tax obligations, Toronto sales tax specialist Simon Thang said June 12.
By TaxChambers LLP
The Crown, on behalf of the CRA, sued TD Bank to recover money that it received from one of its customers.
By TaxChambers LLP
Financial services are generally an exempt supply for which no GST/HST would be charged.
By Vern Krishna
Fresh off the press! Volume 2 of Fundamentals of Canadian Income Tax by Vern Krishna has now been published.
By TaxChambers LLP
With all the excitement concerning the price of cryptocurrencies, individuals and businesses have glossed over the fact that every cryptocurrency transaction is a taxable event that also has revenue...
By TaxChambers LLP
Recent coverage of the U.S. Supreme Court hearing in South Dakota v. Wayfair, Inc. has brought attention to the issue of sales tax on internet sales.
By Vern Krishna
International tax treaties generally tax income from business on a net basis. This contrasts with the taxation of investment income, which is taxed on a gross basis.
Quebec lost $270 million in 2017 from uncollected sales tax on property and services purchased online, according to the proposal.
By Vern Krishna
Bitcoin, writes Vern Krishna, is "a multi-faceted, highly technical and difficult to trace asset that may quite possibly be a pyramid scheme."
By TaxChambers LLP
Bobby Solhi of TaxChambers LLP was quoted by Bloomberg BNA International Tax Monitor on the recent Tax Court of Canada decision in Jayco, Inc. v. The Queen that addressed GST/HST...