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In a short technical interpretation (CRA Document 2015-0579031I7 “Crowdfunding” (April 1, 2015)), the CRA has restated its views on the tax treatment of amounts raised via crowdfunding arrangements. The CRA stated that...more
On April 21, 2015, the Minister of Finance presented Canada’s long-awaited 2015 Federal Budget (the 2015 Budget). The 2015 Budget includes a number of taxpayer-friendly measures, including limited relief from Canadian source...more
Under subsection 152(1.1) of the Income Tax Act, a taxpayer may apply for a determination of losses for a tax year. A taxpayer typically requests a loss determination after the CRA has issued a nil assessment. ...more
TAKE ACTION NOW TO AVOID UNEXPECTED STATE TAX LIABILITIES -
Traditionally, nexus for state income tax liability has required some type of physical presence or continuous contacts by the franchisor/distributor with a...more
The Supreme Court of Canada heard oral arguments today in the case of Guindon v. The Queen (Docket No. 35519). At issue in the case is the nature of the third-party penalty in section 163.2 of the Income Tax Act....more
The transfer pricing case of McKesson v. The Queen has raised procedural issues that are without precedent in Canadian tax cases. This week, those procedural issues became a central part of the matters that will be considered...more
In Maddin v. The Queen (2014 TCC 277), the taxpayer was a director of a corporation in the marble and granite industry (the “Corporation”) which failed to remit nearly $300,000 of source deductions related to salaries, wages...more
The highly-anticipated appeal to the Supreme Court of Canada in Guindon v The Queen has been scheduled for hearing on December 5, 2014, and the parties have now filed their factums in the appeal.
The appeal concerns...more
On October 21, 2014, the British Columbia government introduced Bill 6, the Liquefied Natural Gas Income Tax Act (LNGITA). The LNGITA proposes a two-tier tax on income derived from liquefaction activities at liquefied natural...more
There has been a flurry of recent scrutiny and activity in the areas of foreign and domestic charities – few foreign charities remain on the list of qualified donees since the changes to the definition of “qualified donee” in...more
The small business deduction (“SBD”) is a tax-preference provided to certain privately-held Canadian corporations, and only in respect of certain types of income. More specifically, the SBD provides for a reduction of the...more
We have recently become aware (again) of fake emails purporting to emanate from the CRA and informing the recipient that he/she has received an Interac email money transfer (i.e., a surprise refund).
Treasury automates the process for U.S. taxpayers making an election to defer taxation of Canadian RRSPs and RRIFs and to eliminate some information reporting requirements as to those accounts.
Most tax rectification cases address situations in which a professional advisor has made a mistake in the planning and execution of a transaction with the result that an unintended tax consequence follows (i.e., payment of a...more
The October 4, 2014 Canada Gazette (being vol. 148, no. 40), contained something of note for Canadian film and TV lawyers: amendments to the Income Tax Act regulations which govern the “Canadian content” tax credits for...more
At the heart of tax integration in Canada is the refundable tax and dividend refund mechanism in subsection 129(1) of the Income Tax Act (the “Act”).
Generally, to avoid undue deferral of tax on investment income...more
In Devon Canada Corporation v. The Queen the issue is whether the taxpayer (“Devon”) may deduct $20,884,041 paid to cancel issued stock options. After the close of pleadings, the Crown brought a procedural motion relating to...more
Earlier this year, McKesson Canada Corporation appealed the decision of the Tax Court of Canada in McKesson Canada Corporation v. The Queen (2013 TCC 404) (see Federal Court of Appeal File Nos. A-48-14 and A-49-14).
We have previously blogged about litigation apps and the absence of Canadian litigation and tax litigation apps.
Yesterday, the Canada Revenue Agency introduced a new tool for tax compliance with the release of the...more
While taxpayers have initiated a number of civil claims against the CRA, alleging everything from negligence to fraud, these claims are rarely successful, as courts have traditionally been reluctant to ascribe any duty of...more
On January 10, 2014, McKesson Canada Corporation appealed the decision of the Tax Court of Canada in McKesson Canada Corporation v. The Queen (2013 TCC 404) (see Federal Court of Appeal File Nos. A-48-14 and A-49-14)....more
Subsection 163(1) of the Income Tax Act (the “Act”) imposes a penalty of 10% on an amount that a taxpayer fails to report in his/her return where there has been a previous failure to report income in any of the three...more
At the Toronto Centre Canada Revenue Agency & Tax Professionals Breakfast Seminar on June 10, 2014, the Canada Revenue Agency (“CRA”) provided an update on selected CRA Compliance Measures in the Aggressive Tax Planning...more
When are the parties to a civil tax dispute bound by agreed facts from a criminal proceeding?
This was the question considered by the Tax Court of Canada on a Rule 58 motion made by the taxpayers in McIntrye et al v....more
The Supreme Court of Canada has granted leave to appeal in Guindon v. The Queen (Docket # 35519). In this case, the Supreme Court of Canada will consider whether penalties imposed under section 163.2 of the Income Tax Act...more
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