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Searching Content from Canada indexed under Tax ordered by Published Date Descending.
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1
Significant Changes to GST/HST Holding Company Rules
The Department of Finance released proposed amendments to the Excise Tax Act that could significantly impact holding companies.
Canada
20 Aug 2018
2
A Canadian Court Need Not Recognize A Foreign Court's Rectification Order For It To Bind The Canada Revenue Agency: Canadian Forest Navigation Co. Ltd. v Canada, 2017 FCA 39
Rectification boasts one important difference from a mere amendment. Unlike a document amended by the parties themselves, a rectified document can undo a tax consequence resulting from its pre-rectified form.
Canada
20 Aug 2018
3
Taxation Of Shareholders: The Basic Deemed-Dividend Tax Rules—A Canadian Tax Lawyer's Analysis
These deemed-dividend rules are found in section 84 of Canada's Income Tax Act.
Canada
20 Aug 2018
4
Introduction – The Canada Revenue Agency Responds To The First Stream Of Applications Under The New Voluntary Disclosures Program (VDP)
Yet the IC contemplates that a disclosing taxpayer may require additional time to submit the completed tax returns
Canada
20 Aug 2018
5
Non-Resident Withholding Tax – Interest Income – A Toronto Tax Lawyer Analysis
The Canadian income tax regime differs for resident taxpayers and non-resident taxpayers in Canada.
Canada
20 Aug 2018
6
Determination Of An Individual's Residence Status For Canadian Tax Purposes
As globalization and the use of technology continue to influence the lives and careers of individual taxpayers, often resulting in the requirement to work and/or live in different countries...
Canada
17 Aug 2018
7
Canada Revenue Agency Increases Efforts To Uncover Unreported Cryptocurrency & Offshore Income – A Canadian Tax Lawyer's Analysis
In July 2018, the Canada Revenue Agency announced its progress in exposing those who evade tax by using offshore entities or cryptocurrencies such as Bitcoin, Litecoin, Ethereum, Dash, Zcash, and Ripple.
Canada
17 Aug 2018
8
Federal Court Upholds The Canada Revenue Agency's Audit Powers In The Face Of Charter Challenge: Campbell v Attorney General Of Canada, 2018 FC 683
Campbell v Attorney General of Canada (2018 FC 683) provides yet another example of the futility in resisting a Canada Revenue Agency tax audit.
Canada
17 Aug 2018
9
Sulochana Shantakumar v. Attorney General Of Canada 2018 FC 677 – Case Comment By A Toronto Tax Lawyer On Taxpayer Relief Application
Upon the completion of the Federal Court hearing for Sulochana Shantakumar v. Attorney General of Canada 2018 FC 677 on June 29, 2018, Justice Ahmed decided in the favour of the taxpayer.
Canada
17 Aug 2018
10
21-Year Tax Issues And The Non-Specialist Advisor - Part 3
Part 1 of this Series reviewed what the 21-year deemed disposition rules are and introduced three approaches to planning that appear to be most commonly used to manage the effects of the 21-year deemed disposition rules...
Canada
17 Aug 2018
11
Personal Services Businesses – A Toronto Tax Lawyer Analysis
In Canada, there is a taxation principal of integration which means that, as much as possible, the ultimate tax rate paid on a stream of income is the same regardless of whether it is earned...
Canada
16 Aug 2018
13
The Canadian Taxation Implications For Individual Non-Residents Disposing Of Canadian Real Property- Tax Guide By Canadian Tax Lawyer
The Canadian tax laws addressing the tax of individual non-residents disposing of Canadian real property are, although not drastically different from those imposed in similar transactions...
Canada
16 Aug 2018
14
Tax Settlement Conferences: Rule 126.2 Of The Tax Court Of Canada Rules (General Procedure)—A Canadian Tax Lawyer's Guide
Two types of procedural appeals, informal and general, are available to a taxpayer at the Tax Court of Canada. Tax Settlement Conferences are only available under the general procedure for tax appeals.
Canada
16 Aug 2018
15
Crypto Currency Taxation – Income Tax Implications Of Mining — Toronto Tax Lawyer Analysis
Cryptocurrencies such as Bitcoin or Dash are digital assets which use which use cryptographic techniques to verify the transfer of assets and control the creation of additional units of the crypto currency.
Canada
16 Aug 2018
16
The Trump Transition Tax's Impact On Certain Canadians: A Practical Solution For Ottawa To Consider
The 2017 US tax reform was breathtaking in the speed of its enactment, the breadth of its international provisions, and its complexity.
Canada
16 Aug 2018
17
Excise Tax Act Amendments Released July 2018
On July 27, 2018, the Department of Finance ("Finance") released the Legislative and Regulatory Proposals Relating to the Excise Tax Act
Canada
16 Aug 2018
18
Tax And Real Estate Investment: What Should Non-Residents Investing In Canadian Real Estate Consider?
Any statutory references contained in this article are to the Income Tax Act.
Canada
16 Aug 2018
19
A Refresher On Employer Certification Program – Relief From Canadian Witholding
Canadian tax rules require ALL EMPLOYERS to withhold Canadian income tax from remuneration paid to employees providing services in Canada per Regulation 102 (Reg. 102).
Canada
15 Aug 2018
20
Holding Companies May Face New Rules For GST/HST
The Department of Finance has proposed new "holding corporation rules" for GST/HST* that, if enacted, would be effective as of July 28, 2018.
Canada
15 Aug 2018
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