Normally, the CRA cannot collect any amount of reassessed income tax, interest or penalties while the reassessment is under objection or appeal (although CRA can collect half the reassessed amount, if the taxpayer is a large corporation). However, if there…
In the Canadian domestic tax context, an accrued gain on shares held by one Canadian company in another Canadian company may be safely reduced by the payment of an inter-corporate dividend provided the gain so reduced is attributable to underlying…
Is aggressive tax avoidance immoral? Some people think so, but I don’t. (I’ve been on this topic before – see my blog post, June 5, 2013, “Tax Planning, Morality and Cowboys”). The bottom line for me is this: if…
In 2013-0475261E5, the CRA confirmed that a late eligible dividend designation generally should be possible where an excess capital dividend is (later) treated as a taxable dividend. An eligible dividend paid by a Canadian-controlled private corporation (CCPC) is generally…
In 2012-0439741I7 (released October 23, 2013), the CRA’s Sudbury office considered treating a Canadian company’s preferred share investment in a first-tier foreign affiliate as a loan, with the result that tax-free dividends on the preferred shares were proposed to…
In 2012-0467721R3 (released October 16, 2013), the CRA ruled that a deemed dividend paid by a Canadian unlimited liability company (ULC) to a US parent company qualified for the 5% withholding tax rate under the Canada-US tax treaty (Treaty).…
On October 15, 2013, the Joint Committee made useful submissions to Finance on draft legislation released September 13, 2013 (see http://thor.ca/blog/2013/10/department-of-finance-tax-related-quick-update-report/ for a quick summary of the latter). Among the Joint Committee’s submissions were the following items.
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In 2013-0480321C6, the CRA confirmed its view that US tax levied directly on a Canadian corporate parent (Canco) of a transparent US limited liability company (LLC) would not be deductible or creditable to Canco until such time as the…
On September 13, 2013 the Department of Finance released significant draft legislative proposals. The attached Quick Update Report outlines the corporate tax-related items in this release, which
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It is almost always the case that criminal charges for tax evasion are accompanied by a civil assessment or reassessment of taxes. Often, the fact situation is straightforward. The person earned more income than was declared. The failure to declare…