As a reminder, individuals who carried on a business as a sole proprietor (or spouses of such individuals) are required to file their tax returns by midnight of this Wednesday, June the 15th if they have not already filed on…
Ian Humphries is a partner working out of the Vancouver office of Thorsteinssons LLP.
Ian joined Thorsteinssons after articling and practicing securities law at a national law firm. Prior to law school, Ian worked as an investment banker in the… more »
On Friday, the SCC released its decisions in Canada (Attorney General) v Chambre des notaires du Québec, 2016 SCC 20 (“Notaires”) and Canada (National Revenue) v Thompson, 2016 SCC 21 (“Thompson”).
In Notaires, the CRA had issued demands for documents…
Ian Humphries is a partner working out of the Vancouver office of Thorsteinssons LLP.
Ian joined Thorsteinssons after articling and practicing securities law at a national law firm. Prior to law school, Ian worked as an investment banker in the… more »
In 2015-0594461E5, the CRA indicated that a taxpayer’s intention not to claim a capital gains exemption is irrelevant to the application of the ACB grind under subsection 84.1(2.1) of the Income Tax Act (Canada) which deems a taxpayer to…
Florence Sauve is a partner in the Toronto office of Thorsteinssons LLP.
Florence’s practice focuses on all aspects of taxpayer representation. She assists her clients in managing and resolving tax audit and appeal disputes and represents her clients before the… more »
Paragraph 1.48 of Folio S3-F6-C1 provides that an interest expense on borrowed money used to redeem shares or return capital may be deductible if the borrowed money replaces capital previously used to earn income from a business or property.…
Florence Sauve is a partner in the Toronto office of Thorsteinssons LLP.
Florence’s practice focuses on all aspects of taxpayer representation. She assists her clients in managing and resolving tax audit and appeal disputes and represents her clients before the… more »
In 2015-0572461I7, the CRA indicated that a Canadian resident individual who holds shares in disregarded LLCs through a Canadian LP and a US LP that has elected to be treated as a corporation for US tax purposes is entitled…
Florence Sauve is a partner in the Toronto office of Thorsteinssons LLP.
Florence’s practice focuses on all aspects of taxpayer representation. She assists her clients in managing and resolving tax audit and appeal disputes and represents her clients before the… more »
Paragraph 60(o) of the Income Tax Act (Canada) allows a taxpayer to deduct professional fees “incurred in preparing, instituting or prosecuting an objection to, or an appeal in relation to, an assessment of tax […]”. The CRA recently confirmed that…
Florence Sauve is a partner in the Toronto office of Thorsteinssons LLP.
Florence’s practice focuses on all aspects of taxpayer representation. She assists her clients in managing and resolving tax audit and appeal disputes and represents her clients before the… more »
Under section 150 of the Income Tax Act (Canada), the ordinary deadline for an individual to file a tax return for a taxation year is the following April 30. However, where the deadline falls on a weekend, the CRA’s
Jennifer Flood represents clients in the most high-stakes tax disputes
Jennifer is a partner practicing in the firm’s Vancouver office. She represents companies and individuals in complex tax litigation, in both the civil and criminal contexts. She guides her clients… more »
On April 18, 2016, the Minister of Finance tabled in the House of Commons a Notice of Ways and Means Motion to amend the Income Tax Act and the Excise Tax Act in accordance with certain tax measures announced…
Jennifer Flood represents clients in the most high-stakes tax disputes
Jennifer is a partner practicing in the firm’s Vancouver office. She represents companies and individuals in complex tax litigation, in both the civil and criminal contexts. She guides her clients… more »
On April 11, 2016, the Minister of National Revenue, Diane Lebouthillier gave a press conference on the government’s new initiatives to combat tax avoidance and evasion. The government has committed $444 million to these new programs, which include hiring…
Jennifer Flood represents clients in the most high-stakes tax disputes
Jennifer is a partner practicing in the firm’s Vancouver office. She represents companies and individuals in complex tax litigation, in both the civil and criminal contexts. She guides her clients… more »
In Cuddy v. The Queen, 2016 TCC 76, the Crown took the position that follow-up questions arising from answers to undertakings provided at an oral examination for discovery must be conducted by resuming the oral examination for discovery, unless…
Jennifer Flood represents clients in the most high-stakes tax disputes
Jennifer is a partner practicing in the firm’s Vancouver office. She represents companies and individuals in complex tax litigation, in both the civil and criminal contexts. She guides her clients… more »
