Cadesky Tax is an independent tax consulting firm.

About Cadesky

About Cadesky Tax

We work with a wide range of clients including private businesses, owner-managers, multi-jurisdictional families and businesses, multi-national corporations and high net worth individuals to help them with tax efficient strategies. Our services include estate planning, corporate restructuring, international and Canada-US cross border planning and transfer pricing. Through Cadesky US Tax, we assist with US tax filings.

With our many years of experience, our professional team aims to deliver excellence in tax planning services. In addition to working in tandem with the client’s existing professional team, we have a wide network of professionals in Canada, the US and internationally which allow us to provide seamless services. We work in collaboration with the International Tax Specialist Group (ITSG). This international network enables us to access experienced Tax Professionals in over 30 countries around the Globe.

What's New

Doing Business in the “New” America – A Bigger Opportunity Now, More Than Ever

April 4, 2017

Cadesky Tax is an active member of the American Chamber of Commerce of Canada (“Amcham Canada”). Dean Smith, a former Chair of the Tax Committee, will be taking part on April 4th, in an event entitled “Doing Business in the “New” America – A Bigger Opportunity Now, More Than Ever” where he will discuss various U.S. tax issues that companies need to consider as they expand into the U.S. market place. Additional speakers will discuss, immigration, Homeland Security and How the Halton Economic Region may be of assistance.

Request made to Improve Fairness for Taxpayers with Special Needs

May 19, 2016

The Canada Revenue Agency (CRA) continues to make it increasingly difficult for Canadians with disabilities to access a modest tax credit that means a great deal to people with marginal incomes. "In this area our tax administration is unfair, inefficient and not accountable to anyone," says tax accountant Peter Weissman. "We are concerned about CRA’s disregard not only for its own policies and procedures designed to protect the interests of the taxpayer but also numerous Tax Court of Canada rulings that have provided guidance as far as interpreting the legislative intent of the Income Tax Act."

Towards greater fairness in taxation: international tax advisory bodies present Model Taxpayer Charter

November 13, 2015

Today (13 November 2015), three international professional bodies of tax advisers representing more than 500,000 tax advisers worldwide presented their joint proposal for a Model Taxpayer Charter.

Canada-U.S. Tax Planning for Individuals (Selected Tax Issues)

June 8, 2015

Canadian tax system comparison, Canadian persons with U.S. beneficiaries, U.S. persons with Canadian beneficiaries, Canadians holding U.S. situs assets, U.S. persons holding Canadian assets, Canadians moving to U.S., U.S. persons moving to Canada, U.S. citizens living in Canada.

T1135 Foreign Income Verification Statement

Feb 9, 2015

As of February 9, 2015, individual taxpayers will be able to file this form electronically for the 2014 tax year. The CRA will make electronic filing of Form T1135 available for corporations and partnerships in the future and will announce when the service becomes available.

Canadians regularly going to U.S. for long stays need to be mindful of changes, says MP

Jan 20, 2015

Officials can now track Canadians' exit dates and re-entry dates into Canada. A B.C. MP is warning people about a new information-sharing agreement between Canada and the United States that could put travellers who regularly spend a lot of time in the U.S. at risk of significant consequences...

Government of Canada strengthens collaboration with the United Kingdom

September 9, 2014

The Honourable Kerry-Lynne D. Findlay, P.C., Q.C., M.P., Minister of National Revenue, today wrapped up a successful two-day trip to London, England. During her visit, Minister Findlay met with David Gauke, Financial Secretary to the Treasury for the United Kingdom (U.K.) and responsible for Her Majesty’s Revenue and Customs (HMRC), as well as HMRC senior officials, members of the tax community, and other stakeholders.

Newsletters

GILTI – Partial relief may be coming

Jun 21, 2019

We have described in past US Tax Tips the recently enacted, Global Intangible Low Taxed Income (GILTI) provisions and the potential impacts on United States persons in Canada who own enough shares in Canadian corporations such that those Canadian corporations would be a controlled foreign corporations (CFC) for U.S. tax purposes.

Extending a U.S. Tax Return’s Due Date

Mar 19, 2019

One distinct aspect of the U.S. tax system is the ability for a taxpayer to extend the due date of a tax return. This allows the taxpayer additional time to complete and file an income tax return without being assessed a late filing penalty. Late filing penalties are assessed at the rate of 5% per month up to a maximum of 25%. In most cases a tax return due date can be automatically extended by up to six months. All that is required is the filing of the proper extension form. No explanation from the taxpayer is required and the IRS cannot deny a properly filed extension. However, the timely filing of the form is crucial in order for the extension to be valid.

U.S. Citizens and Sale of Foreign Principal Residence

Feb 25, 2019

For most individuals, their principal residence is their single most important asset. In Canada, when an individual sells their principal residence the gain on the sale is exempt from capital gains tax in most instances. A taxpayer must designate the property as their principal residence when they file their Canadian personal income tax return. This is one of the biggest gifts to individuals in the Income Tax Act…

Housing Deductions – Impacts of the 2017 Tax Cuts and Jobs Act

Feb 15, 2019

The passing of the 2017 Tax Cuts and Jobs Act (TCJA) introduced many changes for taxpayers. Of significant importance for U.S. taxpayers abroad were the repatriation provisions under IRC §965 and the introduction of the new Global Intangible Low Taxed Income (GILTI) regime under IRC §951A. We have discussed and will continue to discuss these provisions as necessary…

The Foreign Tax Compliance Act (FATCA) – It’s happening! FBARs and Form 8938 – A reminder

Jan 29, 2019

There has been much in the news lately about the… Read more »

2019 U.S. Tax Rates

Jan 17, 2019

On November 15, 2018 the IRS issued Revenue Procedure 2018-57. … Read more »

The Multilateral Instrument – The New Preface to the Tax Treaty Brochure

Jul 12, 2019

The use of creative international structures by multinational corporations to transfer a significant portion of their global profits to low tax jurisdictions led the Organisation of Economic Co-operation and Development (“OECD”) to undertake the Base Erosion and Profit Shifting (“BEPS”) study. The study concluded with 15 proposed initiatives, one of which is to address potentially abusive use of tax treaties between countries to shift profits.

When Safe Income Isn’t so Safe

Jun 27, 2019

The Income tax act contains a number of anti-avoidance provisions. Subsection 55(2) apples to convert some intercorporate actual or deemed dividends into capital gains or proceeds of disposition, respectively..

This provision was created when capital gains tax rates were higher than dividends. The intent of the section is to allow companies to move their tax paid retained earnings (“Safe Income”) out of, say, an operating company to a holding company, tax free since intercorporate dividends of this nature are often tax free. There is no further tax paid until the amounts are paid out as dividends to a shareholder who is a “natural person” where the amounts are taxed as eligible or “ineligible” dividends.

Changing Your Corporation’s Fiscal Period

Feb 26, 2019

A Canadian corporation’s first fiscal year can end up to 53 weeks after the date of incorporation. Once the fiscal period has been chosen, it cannot be changed, unless by operation of law, without the permission of the Canada Revenue Agency (“CRA”).

Eaton A.P.A. cancellations were an abuse of I.R.S. discretion

Sep 27, 2017

This article appears in Insights vol. 4, Issue 9.  Insights… Read more »

Amazon makes the CUT – an important taxpayer win, a reminder to consider transactional evidence

May 29, 2017

This article also appears in the May issue of Insights,… Read more »