Tax Law and International Tax Law

A revocable living trust (sometimes called a revocable inter vivos trust) is a legal arrangement you create during your lifetime to hold legal title to your assets.

Estate planning isn't a one-time task—life changes like marriage, divorce, new children, real estate purchases, and shifts in net worth can all impact your plan's effectiveness.

Located in Central America, the Republic of Panama is a politically stable nation characterised by its diverse population.

A recent international law enforcement operation has highlighted the growing scale and sophistication of cryptocurrency fraud, while simultaneously raising complex tax issues for Canadian victims.

Canadian taxpayers, including content creators, influencers, and digital entrepreneurs, who earn income from digital marketing activities—including online advertising through platforms such as Google AdSense, promotional services linked to NFT projects, and sponsorship arrangements with offshore entities—often assume that this income is not subject to GST/HST or is automatically zero-rated because it involves non-Canadian counterparties.

Section 160 of the Income Tax Act (ITA) is one of the most potent collection tools available to the Canada Revenue Agency (CRA). While most tax liabilities are personal to the individual who earned the income, section 160 creates a form of “derivative” or secondary liability.

A corporation, for both general and tax purposes, is recognized as a separate legal entity from its shareholders, unlike a partnership or a sole proprietorship.

As family offices across the Middle East continue to grow in both sophistication and ambition, many are increasingly looking to the United States as a destination for capital deployment.

Cross‑border tax planning typically assumes that if you structure legal agreements correctly and satisfy a tax treaty’s wording, a reduced withholding rate will follow where applicable. Husky Energy Inc.’s (“Husky”) fight with the Canada Revenue Agency suggests that assumption may no longer be safe.

A recent international law enforcement operation has highlighted the growing scale and sophistication of cryptocurrency fraud, while simultaneously raising complex tax issues for Canadian victims.

When a taxpayer misses the deadline to file a notice of objection to a CRA tax reassessment, the situation often feels irreversible. In practice, however, the law does provide a pathway to correct that mistake — but only if the process is followed precisely.

The Scientific Research and Experimental Development (SR&ED) tax incentive program remains Canada’s most significant federal support mechanism for innovation, providing billions annually in SR&ED tax credits to businesses conducting qualifying research and development activities.