The Canada Revenue Agency (the “CRA”) and the Chartered Professional Accountants of Canada (“CPA Canada”) signed an agreement on November 26, 2014. The agreement is intended to promote collaboration and dialogue between the two organizations. The central part of the…
Ken Jiang is a partner at the firm’s Vancouver office.
His practice focuses on corporate and personal tax planning, international tax planning and representation of taxpayers in disputes with Canada Revenue Agency. Ken is fluent and proficient in Chinese (Mandarin).… more »
In 2014-0534671C6, the CRA was asked about its position on D&D Livestock Ltd. v. The Queen 2013 TCC 318. The CRA indicated that it would not hesitate to invoke the GAAR in similar cases involving duplication of tax attributes.
Ken Jiang is a partner at the firm’s Vancouver office.
His practice focuses on corporate and personal tax planning, international tax planning and representation of taxpayers in disputes with Canada Revenue Agency. Ken is fluent and proficient in Chinese (Mandarin).… more »
In 2013-0508651E5, the CRA considered a situation where Canco hired USco to provide services and equipment in Canada. The CRA opined that even if the employees who are providing services to Canco remain on the payroll of USco, Canco…
Ken Jiang is a partner at the firm’s Vancouver office.
His practice focuses on corporate and personal tax planning, international tax planning and representation of taxpayers in disputes with Canada Revenue Agency. Ken is fluent and proficient in Chinese (Mandarin).… more »
In 2014-0550971E5, the CRA was asked to comment on the ownership of a principal residence. For health reasons, the taxpayer’s parents transferred their legal title of their house to the taxpayer, but the parents continued to reside in the…
Ken Jiang is a partner at the firm’s Vancouver office.
His practice focuses on corporate and personal tax planning, international tax planning and representation of taxpayers in disputes with Canada Revenue Agency. Ken is fluent and proficient in Chinese (Mandarin).… more »
In 2014-0543071E5, the CRA was asked whether a taxpayer, who is a Canadian resident, is subject to tax on the gain arising from the disposition of real property located in France. The CRA opined that Article XIII of the…
Ken Jiang is a partner at the firm’s Vancouver office.
His practice focuses on corporate and personal tax planning, international tax planning and representation of taxpayers in disputes with Canada Revenue Agency. Ken is fluent and proficient in Chinese (Mandarin).… more »
On October 1, 2014, the Canada-Honduras Free Trade Agreement and parallel agreements on labour and environmental cooperation entered into force. The free trade agreement eliminates almost 98 percent of each country’s tariff lines. Click here for more information: http://www.international.gc.ca/trade-agreements-accords-commerciaux/agr-acc/honduras/index.aspx?lang=eng
Ken Jiang is a partner at the firm’s Vancouver office.
His practice focuses on corporate and personal tax planning, international tax planning and representation of taxpayers in disputes with Canada Revenue Agency. Ken is fluent and proficient in Chinese (Mandarin).… more »
In the recent decision in Canada v. Brogan Family Trust (2014 ONSC 6354), the Ontario Superior Court of Justice dismissed a motion by the Attorney General of Canada to set aside a rectification order. The court held that the Canada…
Becky Potter is a partner practicing in the firm’s Toronto office.
Becky focuses her practice on all aspects of taxpayer representation and tax litigation. She has successfully represented clients at every level of court both provincially (in Ontario) and federally,… more »
In 2014-0521831R3, the CRA comments on the application of subsection 212(13.2) of the Income Tax Act (Canada) and Article XI of the Canada-US Tax Treaty, in the context of Part XIII withholding tax on interest payments made by the…
Asif Abdulla is a partner working out of the Vancouver office of Thorsteinssons LLP.
He practices in the area of domestic and international tax planning for individuals, trusts, corporations and other private enterprises with a view to achieving tax efficiency… more »
