The so-called “anti-surplus stripping rule” in section 84.1 of the Income Tax Act (Canada) can apply where an individual taxpayer transfers shares of a corporation to another corporation with which the taxpayer does not deal at arm’s length. If the…
Subsection 104(13.4) of the Income Tax Act (the “Act”) will come into effect on January 1, 2016. If not corrected, this provision will have a catastrophic and devastating effect on many estate plans involving alter ego trusts, joint spousal and…
It is an entrenched common law rule that domestic courts must refuse to enforce tax claims of a foreign government (United States of America v. Harden, [1963] SCR 366). This rule, known as the “revenue rule”, was once regarded as…
In 2014-0534841C6, the CRA commented on the definition of majority-interest beneficiary in subsection 251.1(3) of the Income Tax Act. The CRA is of the view that a person does not have to be a beneficiary of a trust to…
The recent decision of Hauser v. R. 2014 TCC 328 is an illustration of the principles to be applied when determining whether moving expenses are deductible. The taxpayer moved in order to have a shorter commute to her new job. …
At the age of 19, Eugenie Bouchard made all Canadians proud with her stellar performance at the 2014 Australian Open. Behind the tennis star is more than a decade’s training paid for by her father. Mr. Bouchard thought he found…