Tax Tips

Jul 19, 2017

Tax Planning Bomb Shell

“Changes to strategies that have been the basis for shareholder… Read more »

Jul 10, 2017

Major changes to the Voluntary Disclosures Program

“relief from penalties will be significantly curtailed” The Voluntary Disclosures… Read more »

Oct 03, 2016

Canadian Tax Treatment of Certain Florida and Delaware Partnerships

the CRA views these entities to be corporations for Canadian… Read more »

Jul 20, 2016

Upstream Loans

taxpayers may need to act now  Prior to 2011, upstream… Read more »

Jan 11, 2016

Voluntary Disclosures – Time is of the Essence

“the initial submission can be made quickly, on a no-names… Read more »

Nov 20, 2015

Special Update on Taxation of Stock Options

“Only new stock options affected by tax changes”, says Minister… Read more »

Nov 17, 2015

Back to the Future

“The expected increase in personal tax rates is significant and… Read more »

Sep 22, 2015

Another Reason to Consider the Disability Tax Credit

  “In order for the election to be valid each… Read more »

Aug 25, 2015

A TeRRIFic Idea

“The re-contribution must be made before March 1, 2016” Generally,… Read more »

Jul 13, 2015

Stock Options

“A small change to timing can have a big tax… Read more »

Jun 29, 2015

Hey, Day Trader

“gains that are treated as income can be taxed at… Read more »

Jun 15, 2015

LLCs for Canadians – Yes, No, Maybe?

“LLC’s may not be the best vehicles for cross-border planning”… Read more »

Feb 24, 2015

US Estate Tax For Canadians?

“securities held in a Canadian brokerage account or registered plan… Read more »

Jan 05, 2015

Inadvertent Transfer of Tax Liability

“The transfer need not be made with the intention of… Read more »

Dec 29, 2014

New Legislation Will Affect Traditional Estate Planning (Part II)

As was mentioned in last week’s Tax Tip, new legislation… Read more »

Dec 22, 2014

The Deceased’s Estate Will Be Required To Pay The Tax Instead of The Trust

“We encourage you to speak with your tax advisor regarding… Read more »

Dec 09, 2014

Immigrant Trusts

“the immigrant trust exemption was withdrawn.” For forty years, Canada… Read more »

Dec 01, 2014

Last Chance to use Losses on Stock Option Shares

“the ability to make this election ends this year.” Typically,… Read more »

Nov 24, 2014

Interprovincial Planning

“There is no set hierarchy of factors that one can… Read more »

Nov 10, 2014

Employee Savings Plans

“A DPSP may be a better way to create a… Read more »

Nov 03, 2014

Source Deduction Waivers

“it is a good idea to start the process now.”… Read more »

Oct 28, 2014

‘Nil Consideration’ Election for GST and HST

“After December 31, 2015, all unfiled elections will be invalid.”… Read more »

Oct 20, 2014

New Rules for Donations by Estates

“It is common for individuals to include charitable bequests in… Read more »

Oct 14, 2014

Year End Planning

“it is better to start planning now, rather than waiting.”… Read more »

Oct 06, 2014

Proposed Changes to Eligible Capital Property Regime

“we expect that the changes will eliminate an important tax… Read more »

Sep 22, 2014

Proposed Legislation Could Affect Traditional Estate Planning

On August 29, 2014, the Department of Finance released a… Read more »

Sep 16, 2014

When Is A Gift Not A Gift?

“The Transferee can be assessed even if he or she… Read more »

Jul 03, 2014

The Capital Gains Exemption

“Capital gains exemption planning is complicated.” A Canadian individual is… Read more »

Jun 27, 2014

IRS Announces Changes to Offshore Programs

“the voluntary compliance window is closing.” On June 18, 2014,… Read more »

Jun 20, 2014

Remuneration Strategy

“If payroll taxes apply, the breakeven point will be even… Read more »

Jun 10, 2014

Employee or Independent Contractor?

“For tax purposes, the answer is very important.” For tax… Read more »

May 28, 2014

Barter Transactions

“Detection is not as hard as it used to be.”… Read more »

Mar 25, 2014

Unhappy Anniversary

“we suggest that… you make note of and track the… Read more »

Mar 04, 2014

Transitional ‘Relief’ For the New Foreign Reporting Forms T1135

“we do not think they go far enough and are… Read more »

Feb 18, 2014

FATCA – The U.S. Wins Hide and Seek

“there will be fewer places for U.S. persons to hide.”… Read more »

Feb 03, 2014

Reporting of International Electronic Funds Transfers

“the Government of Canada is serious about enforcing tax compliance.”… Read more »

Jan 20, 2014

Just What the Doctor Prescribed – The Lowest Rate. Again!

“Seriously consider implementing the plan before the end of March… Read more »

Dec 16, 2013

Charitable Tax Shelters – ‘Tis the Season Redux

“If the charitable tax shelter seems too good to be… Read more »

Nov 18, 2013

Timing Is Everything

“Consideration should be given to paying out capital dividends before… Read more »

Nov 11, 2013

Increase in Capital Gains Exemption

“If commercially practical structure a partial sale of Qualifying Property… Read more »

Oct 28, 2013

Foreign Entity Classifications

“The actual process of classifying an entity for Canadian tax… Read more »

Oct 18, 2013

Dividend Tax Rates Increasing

“Consider paying planned dividends by the end of 2013.” This… Read more »

Oct 11, 2013


“the CRA is now targeting those who receive payments from… Read more »

Oct 04, 2013

Immigrating To Canada – A Tax Checklist

“Some Important Points for the Adviser to Consider.” Many individuals… Read more »

Sep 06, 2013

Happenings in the Tax World

“One of the important roles of tax advisors is to… Read more »

Aug 16, 2013

Prescribed Rate Loans

“the real benefit is the ability to increase the spread… Read more »

Aug 02, 2013

Possible Changes to Graduated Tax Rates for Testamentary Trusts

“the tax and estate planning landscape will be significantly changed… Read more »

Jul 26, 2013

The Window is Closing on Some Voluntary Disclosures

“the clock is ticking for offshore investors.” The Voluntary Disclosures… Read more »

Jun 28, 2013

Expanded Foreign Reporting Requirements

“The level of detail required has been vastly expanded.” In… Read more »

Jun 14, 2013

A REGular Problem

“The payor need not be resident in Canada.” As discussed… Read more »

May 31, 2013

Moving Expenses

“please consult your TSG representative if you have a ‘moving… Read more »

May 17, 2013

Tax Collection Across International Boundaries

“your assets or earnings may be seized to pay the… Read more »

May 03, 2013

‘Offshore’ And ‘Illegal’ Are Not Synonyms

“as long as Canadian tax rules are followed.” The media… Read more »

Mar 15, 2013

Accumulating Corporate Wealth

“The benefit of this strategy is in the use of… Read more »

Feb 22, 2013

Going Rogue

“auditors do not seem to be evaluated based on the… Read more »

Jan 25, 2013

Aggressive Owner-Manager Remuneration

“if it seems ‘too good to be true’, then it… Read more »

Jan 11, 2013

Fiscal Cliff Averted But ‘Fiscal Hill’ Still Remains

“Congress still has to deal with spending cuts.” Over New… Read more »

Dec 28, 2012

Insurance Trusts

“An insurance trust is generally funded outside the estate.” A… Read more »

Dec 21, 2012

Family Employment Insurance

“the overall cost of EI premiums can be significant.” Family-owned… Read more »

Dec 07, 2012

Fiscal Cliff or Fiscal Hill – There is Still a Slope

“Immediate action may be necessary to take advantage of the… Read more »

Nov 30, 2012

CRA Update

“audits of HNW individuals still remain a high priority.” At… Read more »

Nov 23, 2012

Despite Proposed Changes, Scientific Research and Experimental Development (SR&ED) Still Provides Big Benefits for Small Businesses

“it is a good idea to review upcoming SR&ED expenditures… Read more »

Nov 16, 2012

Changes to the ‘Bump’ Rules for Partnership Interests

“partnerships are still a useful vehicle.” A partnership is a… Read more »

Nov 09, 2012

When It’s Not So Great to Donate

“The CRA will neither issue a refund nor assess the… Read more »

Nov 02, 2012

Will You be ABIL to Use Your Capital Gains Exemption?

“It is important to remember the interaction of ABILs and… Read more »

Oct 26, 2012

Uncommon RRSP Rollovers

“Rollovers of Retirement Plan funds are not only available to… Read more »

Oct 19, 2012

Bursaries and Scholarships

“Generally, bursaries are included in income and a deduction for… Read more »

Oct 12, 2012

Third-Party Civil Penalty

“this is not the last word on the matter.” Section… Read more »

Oct 05, 2012

Proposed Changes to Thin Capitalization Rules

“in many cases a portion of existing debt can be… Read more »

Sep 29, 2012

Farm Losses

“the SCC corrected its previous interpretation of the combination test.”… Read more »

Sep 21, 2012

IRS Streamlined Filing Procedures

“These procedures became effective on September 1, 2012.” In Tax… Read more »

Sep 12, 2012

Retiring Outside Canada? Don’t Stay Tax Resident Here

“Residency is based on common law and case law.” Many… Read more »

Sep 07, 2012

Opting Out of Spousal Rollovers

“a taxpayer can opt out of this “rollover” rule.” When… Read more »

Aug 31, 2012

Home Buyer’s Plan Withdrawals

“The ability for a family member to use RRSP funds… Read more »

Aug 24, 2012

Coming to Canada with Stock Options

“it may be beneficial for non-residents to exercise their employee… Read more »

Aug 17, 2012

The Disability Tax Credit

“Identifying eligibility for the DTC can result in thousands of… Read more »

Aug 10, 2012

Sale of property to a trust

“Tax practitioners often recommend the use of trusts.” Tax practitioners… Read more »

Aug 03, 2012

HST or GST and Associated Groups

“the small supplier limit is not measured based on taxable… Read more »

Jul 27, 2012

Allowable Business Investment Losses – Some Good News

“relief from some of the stringent administrative requirements.” We recently… Read more »

Jul 13, 2012

Home Renovations and Construction Cost may be Medical Expenses

“certain alterations to a home or incremental construction costs may… Read more »

Jul 06, 2012

New U.S. Filing Program

“the new procedures should provide some relief.” On June 26,… Read more »

Jun 29, 2012

Transfer of Properties on Separation & Divorce

“It is also important to consider the various attribution rules… Read more »

Jun 15, 2012

Tax Collection Across International Boundaries

“most countries have legislation permitting the enforcement of foreign judgments.”… Read more »

Jun 08, 2012

Relief for Eligible Dividends

“These new rules should generally provide greater flexibility.” Since the… Read more »

Jun 01, 2012

The Capital Gains Exemption – Share Ownership Is Important

“In a typical family estate freeze, this anti-avoidance rule will… Read more »

May 25, 2012

New Rules Affect RRSP’s and RRIF’s Owning Shares of Private Companies

“The ‘prohibited investment’ rules… have significantly impacted RRSP and RRIF… Read more »

May 18, 2012

Corporate ABIL’s

“The type of investor can also impact whether an ABIL… Read more »

May 11, 2012

Post Mortem Pipeline Transactions

“Post Mortem Pipeline Transactions.” As discussed in Tax Tip 10-13,… Read more »

May 04, 2012

Residence of Trusts

“Residence of Trusts.” The Supreme Court of Canada recently confirmed… Read more »

Mar 16, 2012

Changes To Partnership Returns

“There are two changes in this revised version of T5013… Read more »

Mar 09, 2012

Early Exercise of Stock Options

“it is desirable to minimize the employment benefit and increase… Read more »

Mar 02, 2012

The 2012 Federal Budget

“Your TSG members will be reviewing and analyzing the 2012… Read more »

Feb 17, 2012

New RRSP Investment Rules

“Advisors should review these new rules with clients who are… Read more »

Feb 10, 2012

RRSP Deductions

“”The timing of the RRSP deduction can result in significant… Read more »

Feb 04, 2012

Joint Venture Fiscal Period Changes

“CRA Revises Joint Venture Administrative Policy.” The Canada Revenue Agency… Read more »

Jan 27, 2012

New CPP Rules

“These new rules have an impact on remuneration planning for… Read more »

Jan 20, 2012

New 2012 OVDI for US Taxpayers

“continuing to delay or ignore any catch up U.S. filings… Read more »

Jan 06, 2012

Dual Citizens Receive New Guidance from the IRS

“”non-filers can take some comfort that they will not automatically… Read more »

Dec 23, 2011

‘Tis the Season for Charitable Tax Shelters – Beware!

“If the charitable tax shelter seems too good to be… Read more »

Dec 09, 2011

Canadian Residents Leaving Canada Permanently – A Key Tax Point

“The tax cost plus interest and penalties for non-reporting can… Read more »

Dec 02, 2011

Negative Adjusted Cost of Limited Partnership Interest

“Often the negative consequences can be avoided by delaying the… Read more »

Nov 25, 2011

Health Care Spending Accounts

“To qualify, the plan must be made available to all… Read more »

Nov 18, 2011

Deferred Payment of Tax on Death

“The prescribed rate does not fluctuate over the deferral term.”… Read more »

Nov 11, 2011

Child Care Expenses

“amounts paid to grandparents could qualify.” The Income Tax Act… Read more »

Nov 04, 2011

Personal Services Business Corporations Under Attack

“technical amendments will eliminate any current deferral opportunities with PSB’s.”… Read more »

Oct 28, 2011

Foreign Employees Working in Canada

“Waiver requests are not usually granted retroactively.” Regulation 102 requires… Read more »

Oct 21, 2011

Acquisitions of Control and Losses

“”non-capital losses often include losses from property”.” The Income Tax… Read more »

Oct 14, 2011

Instalments After an Amalgamation or Wind-Up

“Most tax preparation software does not update instalment schedules..” For… Read more »

Oct 07, 2011

Expansion of the Kiddie Tax Rules to Capital Gains

“they would appear to apply to crystallization transactions.” The Income… Read more »

Sep 30, 2011

Principal Residence in a Trust

“”accessing the exemption through a trust is not always possible”.”… Read more »

Sep 16, 2011

Section 84.1 Can Happen To You

“Section 84.1 assessments are a major cause of litigation.” Section… Read more »

Sep 12, 2011

Schedule 91- More Than Just a Treaty Based Return

“We have found that the CRA is using schedule 91… Read more »

Aug 22, 2011

Charitable Remainder Trust

“the guaranteed current use of the donation receipt makes the… Read more »

Aug 12, 2011

Attribution Rules

“”second generation” income is not attributed back to the original… Read more »

Aug 05, 2011

Deadline Looms for Non-Compliant US Taxpayers

““It is uncertain if the IRS will continue to assess… Read more »

Jul 29, 2011

Relying on Draft Legislation

“CRA expects taxpayers to comply with draft legislation.”  Proposed changes… Read more »

Jul 22, 2011

Registered Disability Savings Plan (“RDSP”)

“an individual will be able to carry forward unused grant… Read more »

Jul 15, 2011

GST/HST On Medical Fees

“GST/HST may apply to other services provided by a practitioner.”… Read more »

Jul 08, 2011

Hiring Non-Residents for Temporary Employment in Canada

“The employer must calculate, withhold and remit tax based on… Read more »

Jun 24, 2011

Testamentary Planning – The Power of a Dollar

“This creative estate planning technique can create a legacy of… Read more »

Jun 17, 2011

A New Playing Field for Waiver of Interest and Penalty

“The ten-year rule refers to the years during which the… Read more »

Jun 10, 2011

IRS Appears to Be Providing Some Relief to Innocent Non-Filers

“Penalties may be eliminated.” In Tax Tip 11-05 we reported… Read more »

Mar 18, 2011

U.S. Tax Treatment of Tax-Free Saving Accounts

“Income earned in a TFSA is taxable on a current… Read more »

Mar 04, 2011

Failure to Report a Capital Gain

“One can never know for sure which way the Tax… Read more »

Feb 18, 2011

Innocent Non-Compliant U.S. Tax Filers

“These changes will make it easier for the IRS to… Read more »

Feb 11, 2011

New IRS Offshore Voluntary Compliance Initiative

“The IRS believes the 2011 initiative offers clear benefits.” On… Read more »

Feb 04, 2011

Canadian Treatment of U.S. Roth IRA’s Is Changing

“The election is invalid on a go-forward basis.” Canadian residents… Read more »

Jan 28, 2011

Get A Grip

“It may save time and effort for such a CCPC… Read more »

Jan 21, 2011

Losing CCPC Status

“it is important to plan in advance.” There are a… Read more »

Jan 07, 2011

Payroll Implications of an Amalgamation Are Different From Those of a Wind-Up

“If these special deadlines are not met on the wind-up… Read more »

Dec 17, 2010

Out of Country Medical Expenses

“Experimental procedures that are not available locally can be eligible.”… Read more »

Dec 10, 2010

Leaving Canada

“The Canada Revenue Agency has been attacking claims of Canadian… Read more »

Dec 03, 2010

Alter Ego Trust as a Will Substitute

“such trusts provide for incapacity planning” While an earlier Tax… Read more »

Nov 12, 2010

Acquisition of Control – Choose Your Trustees Carefully

“It is uncertain whether the CRA’s policy is correct, as… Read more »

Oct 22, 2010

Impact of IFRS on Canadian Tax

“IFRS would require a previously unnecessary tax adjustment.” All Canadian… Read more »

Oct 08, 2010

Unpaid Fees

“Even though late filing of the form is allowed, it… Read more »

Sep 23, 2010

New Filing Requirements for Partnerships

“Partnerships that never filed before may now have to.” The… Read more »

Sep 14, 2010

New Rules Regarding Stock Options

“Most employers will not want to elect out of the… Read more »

Aug 31, 2010

Section 116 Certificates & Section 212.1

“relief from one provision of the ITA does not mean… Read more »

Aug 25, 2010

Accessing The Capital Gains Exemption

“initially structuring the business as a sole proprietorship or partnership…… Read more »

Aug 13, 2010

Making Maximum Use of Charitable Donations on Death

“build flexibility into the deceased’s Will.” People often make their… Read more »

Aug 09, 2010

Capital Gains Realized On Emigrating From Canada

“relief from the tax on departure may be available.” Upon… Read more »

Jul 30, 2010

Allowable Business Investment Losses And The Capital Dividend Account

“An ABIL claimed by a corporation reduces the corporation’s CDA.”… Read more »

Jul 09, 2010

Non-Refundable Dividend Tax On Hand

“the result can be the equivalent of ‘triple tax’.” The… Read more »

Jul 02, 2010

Spousal Trust Strategy

“”asset-building” can be particularly effective.” A “spouse trust” can be… Read more »

Jun 25, 2010

Alter Ego And Joint Partner Trusts

“Such a trust can provide estate planning benefits” Canadian residents… Read more »

Jun 18, 2010

Traps In Crystallizations

“potential pitfalls can result in unexpected, costly mistakes.” Capital gains… Read more »

Jun 04, 2010

Rental Property CCA Restriction Applies On Aggregate Basis

“X will lose out on claiming $60 of available losses… Read more »

May 28, 2010

Change to Post Mortem Planning

“sometimes traditional planning techniques become outdated.” As we alluded to… Read more »

May 21, 2010

Expanded Reporting Requirement For Foreign Assets

“The penalty could apply on a per-item basis.” Over the… Read more »

May 14, 2010

Personal Service Businesses

“”the combined tax bill can be significantly lower than the… Read more »

May 07, 2010

Stock Option Tax Deferral Election

“The 2010 Federal Budget proposes to repeal the employee stock… Read more »

Mar 22, 2010

Transfers of Investments to Corporations

“If Mr. X had retained and sold the investment, there… Read more »

Mar 12, 2010

Subsection 17(1) Income Inclusions

“Loans to non-residents can cause income inclusions.” Subsection 17(1) of… Read more »

Feb 26, 2010

Directors’ Fees Paid to Non-Residents

“This withholding tax requirement is often overlooked.” In a recent… Read more »

Feb 12, 2010

Scientific Research & Experimental Development

“Early identification and good documentation are critical.” The Scientific Research… Read more »

Feb 05, 2010

Severe Penalties for Not Reporting Foreign Property

“Form T1135 includes a certificate of full disclosure to be… Read more »

Jan 29, 2010

U.S. Citizens in Canada

“U.S. status could eliminate many Canadian tax benefits.” Canada taxes… Read more »

Jan 22, 2010

Canada Revenue Agency and Income Splitting Trusts

“The CRA has decided to actively audit domestic inter vivos… Read more »

Jan 15, 2010

Using an RRSP as Security

“Using an RRSP as security for a loan may be… Read more »

Jan 08, 2010

Deductions for Tradespersons’ & Apprentice Mechanics’ Tools

“Two deductions may be available to individuals.” Two deductions may… Read more »

Dec 18, 2009

Unclaimed Capital Losses

“Identifying unreported capital losses from prior years can result in… Read more »

Dec 14, 2009

Tax Savings For U.S. Residents Selling Canadian Capital Property

“Part of the gain may be exempt from Canadian tax.”… Read more »

Dec 11, 2009

Electing Out of a Spousal Rollover on Death

“The decision whether to elect out of the spousal rollover… Read more »

Nov 16, 2009

Funding The Testamentary Trust

“When assets are jointly titled, they do not pass through… Read more »

Nov 06, 2009

Testamentary Planning

“You should consider creating a testamentary trust as part of… Read more »

Oct 30, 2009

Claiming Capital Losses

“It may be advisable for the lender to charge a… Read more »

Oct 23, 2009

CRA Announces Policy Changes for Employee Benefits (AMENDED Dec 17, 2009)

“The Canada Revenue Agency (CRA) has announced policy changes for… Read more »

Oct 16, 2009

Election to Dispose of Property

“There is no prescribed form for the 50(1) election.” The… Read more »

Oct 09, 2009

Reducing Tax Withheld at Source

“‘it is a good idea to start the process now’.”… Read more »

Sep 25, 2009

HST Planning For Ontario and British Columbia

“Businesses that purchase equipment or other capital goods that bear… Read more »

Sep 11, 2009

Inadvertent Transfer of Tax Liability

“The transfer need not be made with the intention of… Read more »

Aug 10, 2009

Possible rebate for GST Paid on Certain Investment Management Fees

“Do not be surprised if the rebate claim is denied.”… Read more »

Jul 24, 2009

Form 5471 Penalty

“The $10,000 penalty will be assessed automatically against corporate taxpayers.”… Read more »

Jun 19, 2009

Notices of Objection for Individuals

“A taxpayer can object to a notice of assessment even… Read more »

Jun 08, 2009

Fewer Taxpayers Required to File US Treasury Reporting Form

“The IRS announced that it is suspending the expanded definition… Read more »

May 15, 2009

Canadian Individual Taxation Numbers

“The ITN is a nine-digit number issued by the CRA… Read more »

May 08, 2009

Election for Accelerated CCA on Buildings

“The eligibility for the higher CCA rate is not automatic.”… Read more »

Apr 09, 2009

Source Deduction Waivers

“The CRA will authorize a reduction in tax withheld if… Read more »

Apr 03, 2009

Refunds of Withholding Tax

“The credit for foreign taxes will likely be based on… Read more »

Mar 27, 2009

Income Splitting

“Make sure the correct amount of interest is paid by… Read more »

Mar 20, 2009

Health & Welfare Trusts

“Where expenses are significant, the savings outweigh the costs.” Most… Read more »

Mar 13, 2009

Principal Residence Exemption

“If you own more than one property, keeping track of… Read more »

Mar 06, 2009

Payment of Capital Dividends

“It may be prudent to consider paying a capital dividend… Read more »

Feb 27, 2009

To TFSA or Not To TFSA: That Is The Question

“The rule of thumb is to invest in an RRSP… Read more »

Feb 20, 2009

Creditor Proofing

“Equity may include inherent goodwill that is not reflected on… Read more »

Feb 13, 2009

Non-Residents Can Use Subsection 164(6)

“This election will not be available on property held in… Read more »

Feb 06, 2009

The Tax-Free Savings Account

“The TFSA program offers taxpayers an opportunity to earn investment… Read more »

Jan 28, 2009

Changes to US Treasury Department Reporting Requirements

“You should be aware of the expanded base of those… Read more »

Dec 05, 2008

Timing of Acquisition of Control

“The failure to elect out of subsection 256(9) can result… Read more »

Nov 28, 2008

Pension Income Can Be Split in Year of Death

“Eligible pension income relating to the portion of the year… Read more »

Nov 07, 2008

Restrictive Covenants

“Don’t Ignore the Proposed Restrictive Covenant Legislation.” The restrictive covenant… Read more »

Sep 19, 2008

Child Fitness Amount

“The CRA website may refer to the new requirements but… Read more »

Aug 15, 2008

Personal Service Businesses

“Be sure before concluding that the PSB rules do not… Read more »

Aug 01, 2008

Transfer of Life Insurance to a Child

“Transfer to the guardian for an incapacitated child will not… Read more »

Jul 18, 2008

A Return to Partnerships

“Start the clock ticking by filing a T5013.” Partnerships do… Read more »

Apr 11, 2008

Medical and Disability Related Matters

“Opportunities for your clients.” Many professionals are not well versed… Read more »

Mar 07, 2008

High Investment Income Reduces SR&ED Expenditure Pool

“Investment income can reduce a company’s ability to claim refundable… Read more »

Feb 08, 2008

Moving Expenses

“Complicated rules for a simple situation.” When an individual moves… Read more »

Jan 25, 2008

Eligible Dividends And Real Estate Companies

“Old rules of thumb need to be re-examined carefully.” The… Read more »

Jan 18, 2008

The Capital Gains Exemption And Incorporating Professionals

“Sale of sole proprietor can be tax-free with planning.” The… Read more »

Dec 14, 2007

5th Protocol – Canada-US Income Tax Convention – Interest Withholding Tax – Non-Arm’s Length

“Elimination of withholding tax will apply to interest payments by… Read more »

Dec 10, 2007

Wind-Up vs. Amalgamation: A Big Difference

“Whether an amalgamation or a wind-up is chosen, the tax… Read more »

Dec 03, 2007

New Info Circular on Voluntary Disclosures

“The processing time of voluntary disclosures will be increased without… Read more »

Nov 23, 2007

Foreign Operations & The Capital Gains Exemption

“Shares of foreign corporations may render a corporation ineligible for… Read more »

Nov 09, 2007

Fifth Protocol – Canada-U.S. Tax Treaty – Stock Options

“The revised Protocol provides a mechanism for allocating stock option… Read more »

Nov 02, 2007

Halloween Tricks ‘n Treats – The Federal Economic Statement

“Proper planning can result in benefits to both sides.” On… Read more »

Oct 05, 2007

Leasehold Inducements

“Tax treatment does not automatically follow the accounting treatment for… Read more »

Jun 15, 2007

Attribution of Property on Marital Breakdown

“Filing the appropriate elections is necessary to ensure that an… Read more »

Jun 08, 2007

Transfer of Properties on Separation & Divorce

“Proper planning can result in benefits to both sides.” When… Read more »

Mar 16, 2007

GAAR – Reasons For Transaction

“Having a business transaction may preclude GAAR when tax is… Read more »

Mar 09, 2007

New CRA Receipt Policy Worrisome To SR&ED Filers

“File early to allow CRA enough time to confirm all… Read more »

Mar 02, 2007

When CRA Does Not Like the Results, GAAR Is Applied

“The CRA will use GAAR to overcome a decision they… Read more »

Feb 23, 2007

Be Careful if You Allocate Partnership Income Only to Reduce Tax

“The CRA can reallocate partnership income allocations when they consider… Read more »

Feb 16, 2007

Transit Pass Credit & Fitness Tax Credit

“The transit pass credit is for 2006 and the fitness… Read more »

Jan 26, 2007

Separate Class for Rental Buildings

“The allocation of purchase price is important on the purchase… Read more »

Jan 19, 2007

Attribution Rules – Spousal Loans

“Attribution can be avoided on spousal loans in certain situations.”… Read more »

Dec 29, 2006

Designation of Eligible Dividends – 2006/2007

“CRA gives guidance on 2006 and 2007 eligible dividend designations.”… Read more »

Dec 22, 2006

Eligible Dividends – Years Prior To 2006

“Inter-company dividends must be reviewed carefully for years between 2000… Read more »

Dec 15, 2006

Penalty and Refund Changes

“Refunds could be unexpectedly withheld.” The CRA recently sent out… Read more »

Dec 08, 2006

Withholding Tax on Remuneration Paid to Non-Residents of Canada

“Without planning, non-resident employers could be subject to unexpected taxes.”… Read more »

Dec 01, 2006

GST on Disbursements

“Taxation of disbursements depends on whether the professional is an… Read more »

Nov 24, 2006

Sale of Shares Deemed Business Income

“Facts are key to determine tax treatment of share sales,… Read more »

Nov 10, 2006

Government’s Annoucement on Income Trusts & Pension Income

“New rules for income trusts and pension income.” The Federal… Read more »

Nov 03, 2006

Capital Cost Allowance – Separate Classes

“In some cases, assets can, or must, be placed in… Read more »

Oct 27, 2006

Rental Property – Capital Cost Restrictions

“Capital cost allowance on rental properties can be restricted to… Read more »

Oct 20, 2006

Meals & Entertainment – 100% Deductible

“In some cases, meals and entertainment expenses can be 100%… Read more »

Oct 13, 2006

Capital Gain Reserves

“Capital Gains are taxable over five or ten years depending… Read more »

Oct 06, 2006

RRSP Ineligible Investments

“There can be a high cost to purchasing ineligible investments… Read more »

Sep 29, 2006

Principal Residence – What Needs to be Filed

“You do not need to complete T2091 unless there is… Read more »

Sep 22, 2006

GAAR & International Tax Treaties

“CRA loses landmark case on application of GAAR to an… Read more »

Sep 15, 2006

163(2) Gross Negligence Penalty

“Can an accountant’s gross negligence transfer to the client?.” In… Read more »

Sep 08, 2006

Ontario Response to Federal Dividend Tax Changes

“Ontario has decided to gradually introduce the reduced dividend tax… Read more »

Aug 11, 2006

Shareholder Benefits – Bookkeeping Errors

“Bookkeeping errors to the benefit of a shareholder are not… Read more »

Aug 04, 2006

Loss Determinations

“A loss determination cannot be used to claim losses not… Read more »

Jul 21, 2006

Can You Be Resident in More Than One Place?

“An individual’s residency often depends on his ties to a… Read more »

Jul 14, 2006

How Much Are Non-Monetary Benefits Worth?

“In determining tax liability under s. 160, non-monetary transfers must… Read more »

Jul 07, 2006

Active Business Vs.Investment Business

“Past History and intention is relevant in determining if company… Read more »

Jun 30, 2006

163(2) Ignorance Could Have Been Bliss

“If you receive tax advice and disregard it, you are… Read more »

Jun 23, 2006

When is Debt Uncollectible Debt

“What is required to determine when a debt is uncollectible?.”… Read more »

Jun 16, 2006

Eligibility for the Tuition Credit

“Do you need a physical presence to be eligible for… Read more »

Jun 09, 2006

Deductibility of Legal Expenses

“Subsection 60(o) allows for the deductibility of legal payments for… Read more »

May 05, 2006

Budget 2006 – Dividend Rates as Promised

“The 2006 Budget has clarified how eligible dividends will be… Read more »

Mar 24, 2006

GST on Property Taxes Paid by Tenants

“Do you have clients who have commercial tenants who pay… Read more »

Mar 17, 2006

Professional Incorporation Update

“Holding companies cannot be used to hold shares of a… Read more »

Mar 10, 2006

Fairness & Late Filing Penalties

“Late-filing penalties were referred back to CRA because all taxes… Read more »

Mar 03, 2006

Stock Option Deductions

“Payments to an employment consultant are not permissible deductions from… Read more »

Feb 24, 2006

GAAR – Using Attribution to the Taxpayer’s Benefit

“Using attribution to your benefit is not GAAR.” In the… Read more »

Feb 10, 2006

Due Date of Corporate Taxes

“The due date of corporate taxes depends on many factors.”… Read more »

Feb 03, 2006

Professional Incorporation – Doctors’ & Dentists’ Family Members

“There are new changes to the OBCA allowing family members… Read more »

Jan 27, 2006

Allowable Business Investment Losses – Payments to Individuals in Trust for Companies

“Payments to individuals on behalf of companies may still be… Read more »

Jan 20, 2006

Capital Dividend Account (CDA) and Eligible Capital Expenditures (ECE) – Beware

“CDA payments related to ECE cannot be paid until the… Read more »

Jan 13, 2006

Withholding Tax Rates to Non-Resident Trusts & Their Beneficiaries

“The CRA has revised their policy on payments to non-resident… Read more »

Dec 16, 2005

First GAAR Case After Supreme Court Decision

“The Evans case clarifies the practical application of GAAR.” A… Read more »

Dec 02, 2005

New Dividend Rates

“The new dividend tax rates will affect owner/manager clients.” On… Read more »

Nov 25, 2005

SR&ED/Stock Option #2

“Proposed Amendments to deny stock option benefit in ITC calculation.”… Read more »

Nov 18, 2005

Fairness Provisions

“If CRA does not consider all facts, the courts are… Read more »

Nov 11, 2005

Association – Control in Fact

“Control in fact must be determined by considering all relevant… Read more »

Nov 04, 2005

When is an Amount Paid in Order to Be a Deduction?

“Can a taxpayer deduct an amount he didn’t pay directly?.”… Read more »

Oct 28, 2005

Change of Control – Trustees

“A change of trustees could result in a change of… Read more »

Oct 21, 2005

CCA & Beneficial Ownership

“Ownership by a spouse does not preclude CCA and related… Read more »

Oct 14, 2005

Voluntary Disclosure – On a No-Name Basis

“There is a 90-day limit to disclose the taxpayer’s name.”… Read more »

Sep 30, 2005

U.S. Companies Investing in Canada

“Be aware of using U.S. LLC’s to hold shares in… Read more »

Sep 23, 2005

Stock Option Deferral – Cost Base Calculations

“Detailed records are necessary to calculate the cost base of… Read more »

Sep 16, 2005

Employees Profit Sharing Plans

“EPSP’s do not work in all situations.” There have been… Read more »

Sep 09, 2005

SR&ED Claim for Stock Option Benefit

“Stock option benefit can be used for ITC calculation.” The… Read more »

Aug 12, 2005

When a Hotel Is Not a Lodge – 18(l)

“The CRA lost their argument that country hotels are lodges.”… Read more »

Aug 05, 2005

Analysis of “Arm’s Length”

“CRA lost in its approach that any transactions that reduce… Read more »

Jul 25, 2005

Residency Test – Allchin Revisited

“Tax Court forced to take a second look at this… Read more »

Jul 15, 2005

Alberta Unlimited Liability Company (“ABULC”)

“ABULC’s are cost-effective alternatives to NSULC’s.” Until May 2005, US… Read more »

Jul 11, 2005

Federal Court Makes Decision on Voluntary Disclosures

“No-names basis submission that was accepted by CRA cannot be… Read more »

Jun 16, 2005

Salaries & Bonuses To Family Members

“In-kind payments are acceptable and so are large bonuses to… Read more »

Jun 03, 2005

Personal Health Service Plans – The Story Continues

“The health plan must be available to employees, not just… Read more »

May 27, 2005

Professional Corporations – Doctors and Dentists

“New rules allow for non-family members to be shareholders..” In… Read more »

Apr 15, 2005

Dividend Refund in Statute-Barred Years Cannot Be Adjusted

Apr 08, 2005

Were They Thinking?

“Unfortunately, sometimes a case has to go to Court for… Read more »

Apr 01, 2005

Application of Fairness Provision in Court

“The fairness guidelines issued by CRA do not apply to… Read more »

Mar 25, 2005

The Price of Not Reporting Stock Options

“A taxpayer is required to include the proper amount in… Read more »

Mar 18, 2005

Contractor Vs. Employee

“This issue requires a review of all relevant factors..” Whether… Read more »

Mar 11, 2005

Tax-Free Spousal Transfer

“In order for a special transfer to be tax-free, the… Read more »

Mar 04, 2005

Terminal Losses For Estates

“Terminal losses in the first year of an estate can… Read more »

Feb 25, 2005

Using Stop-Loss Rules To Your Benefit

“Spousal transfers can result in transfer of cost base..” There… Read more »

Jan 28, 2005

Deferral of Tax Payments on Death

“If the proper elections and arrangements are made, tax payments… Read more »

Jan 21, 2005

All or Substantially All – What Does It Mean?

“CRA’s interpretation may not be same as the Tax Court’s..”… Read more »

Jan 14, 2005

U.S. Corporate Filing Requirements

“Treaty protection does not mean there are no US tax… Read more »

Jan 07, 2005

Revised Stop-Loss Rules For Post Mortem Planning

“Proposed rules allow post mortem estate planning..” Subsection 40(3.6) is… Read more »

Jan 02, 2005

2005 Tsunami Donations Can Be Used in 2004

“Donations must be to certain charities only, before January 12,… Read more »

Dec 10, 2004

Large Corporations Tax Issue

“Un-presented cheques should not be included in taxable capital..” In… Read more »

Dec 03, 2004

Single Purpose Corporations – New Proposals

“CRA has issued a new administrative policy on single purpose… Read more »

Nov 19, 2004

CRA Disputes

“Information available for a notice of objection..” Whenever a taxpayer… Read more »

Nov 12, 2004

Allowable Business Investment Losses

“Issues To Consider.” A business investment loss (BIL) arises from… Read more »

Nov 05, 2004

Fairness Rules – December 2004 Deadline

“All files should be checked..” Generally speaking, the Fairness Rules… Read more »

Oct 22, 2004

Registered Education Savings Plans

“RESP’s – a good vehicle to save for a child’s… Read more »

Oct 15, 2004

Residency Test

“Tax treaties should be considered in determining whether an individual… Read more »

Oct 08, 2004

Deductibility of Management Bonus

“Be aware of CRA policy on deductibility of management bonuses..”… Read more »

Sep 24, 2004

Withholding Tax For Services Done – By Non-Residents in Canada

“A 15% withholding tax may be payable for services rendered… Read more »

Sep 17, 2004

Deemed Association

“Shares held by trusts or minors could have adverse results… Read more »

Sep 03, 2004

Attribution That Works

“Low Prescribed Rates Allow for Income Splitting.” The third quarter… Read more »

Aug 06, 2004

Evidence Required

“Sometimes evidence accepted by Courts is different from the CRA..”… Read more »

Jul 30, 2004

Personal Health Service Plans and Shareholder Benefits

“There could be shareholder benefits and non-deductible payments for PHSP’s..”… Read more »

Jul 23, 2004

Disassociating Companies

“Using a specified class of shares can disassociate companies..” There… Read more »

Jul 16, 2004

Foreign Social Security Taxes As Foreign Tax Credits

“For countries other than U.S., the foreign social security taxes… Read more »

Jul 09, 2004

Single Purpose Corporations

“CRA has changed its administrative position for companies owning U.S…. Read more »

Jul 02, 2004

Loans To Family Members

“Certain conditions are necessary to claim capital losses on loans… Read more »

Jun 25, 2004

Overpayment of U.S. Taxes May Prohibit Claim of Foreign Tax Credit

“Taxpayers must ensure that they only pay the withholding rate… Read more »

Jun 18, 2004

Supreme Court Decision – Gifford

“This Supreme Court case is relevant for the purchase of… Read more »

Jun 11, 2004

Death Benefits

“Tax-free payments are permitted in certain situations..” There are few… Read more »

Jun 04, 2004

Subsection 75(2) – Planning To Avoid

“It is important to carefully draft trusts to avoid unwanted… Read more »

May 28, 2004

Alternative To Alter-Ego Trusts

“Self Benefit trusts may help those under 65 in dealing… Read more »

May 21, 2004

Planning For the 21-Year Deemed Disposition Rule

“Planning is required before the deemed disposition rules apply.” Most… Read more »

Apr 02, 2004

Partnerships – Not Statute-Barred If No T5013 Filed

“Filing a Partnership ReturnEnsures Partnership Income becomesStatute-Barred.” A Canadian partnership… Read more »

Mar 26, 2004

Claiming Losses on Shares or Debt

“Shares or debt of corporations can be claimed as a… Read more »

Mar 19, 2004

Professional Corporations – Year Ends

“It is possible to restructure to allow a professional corporation… Read more »

Mar 12, 2004

Financing Fees / Borrowings – Partnership

“When interest is deductible within a partnership and financing fees… Read more »

Mar 05, 2004

Change in Use / Principal Residence

“Be Aware of Changing a Principal Residence to Investment Property… Read more »

Feb 24, 2004

Donations Schemes – Some Reasonable Conclusions

“Klotz Case Reviews Art Flips to Charities.” In a recent… Read more »

Jan 23, 2004

Employee Benefits

“Free Meals and Gifts.” There was a recent case (McGoldrick),… Read more »

Jan 16, 2004

Proposed Charitable Donation Rules (#2)

“Advantages Received by the Donor.” Further to the recent Tax… Read more »

Jan 09, 2004

Proposed Charitable Donation Rules (#1)

“Government has limited access to donation receipts..” On Friday December… Read more »

Dec 19, 2003

Year-End Tax Planning Considerations

“Year-End Tips.” As we approach December 31st, it is time… Read more »

Dec 17, 2003

Review of Capital Loss Rules

“Year-End Planning Considerations.” There may be taxpayers who have realized… Read more »

Nov 28, 2003

Definition of Common Law Spouse

“Living together makes you married for tax purposes..” Being a… Read more »

Nov 21, 2003


“Circumstances where reserves cannot be claimed are extended..” In general,… Read more »