Tax Alert Archives

CRA comments on whether the premium on the redemption of foreign affiliate shares is a dividend or proceeds of disposition

In 2014-0528361E5, the CRA responded to a query in respect of previous Rulings document 2012-0439741I7 which had indicated that the premium on redemption of certain foreign affiliate shares (mandatory redeemable preference shares) would be characterized as a dividend. …

Prepared by: Asif Abdulla

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 »

Share

Former CRA Employee Fined and Sentenced to 18-month Conditional Sentence for Income Tax Evasion

Former CRA Employee Fined and Sentenced to 18-month Conditional Sentence for Income Tax Evasion. Click here for more information.

Prepared by: Asif Abdulla

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 »

Share

Department of Finance – Annual Financial Report Released

On October 6, 2014 the Department of Finance Released its Annual Financial Report for the Fiscal Year 2013-2014 and the Backgrounder: Highlights From the Annual Financial Report for 2013-14

Prepared by: Asif Abdulla

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 »

Share

OECD Releases First BEPS Recommendations

On September 16, 2014, the OECD released its first recommendations as part of the Base Erosion and Profit Shifting Project (“BEPS”), covering the following topics:

  1. Addressing the tax challenges of the digital economy;
  2. Ensuring the coherence of corporate income

Share

Canada Revenue Agency Provides Comments on Taxation of Settlement Payments

In 2014-0522921E5, the CRA provides general comments on taxation of settlement payments. The CRA’s position is that whether a settlement payment is taxable is a question of fact based on the nature and purpose of the settlement payment and…

Prepared by: Shawn Tryon

Shawn is a partner practicing in the firm’s Vancouver office. His practice focuses on both tax planning for individuals and businesses as well as audit representation and tax litigation matters. On audit representation and tax litigation matters, Shawn has extensive… more »

Share

Canada Revenue Agency Releases Income Tax Folio Regarding Support Payments

Income Tax Folio S1-F3-C3 replaces and cancels Interpretation Bulletin IT-530R, Support Payments, and Income Tax Technical News No. 24.  This Income Tax Folio has a three month comment period, ending November 19, 2014.  Income Tax Folio

Prepared by: Shawn Tryon

Shawn is a partner practicing in the firm’s Vancouver office. His practice focuses on both tax planning for individuals and businesses as well as audit representation and tax litigation matters. On audit representation and tax litigation matters, Shawn has extensive… more »

Share

Canada Revenue Agency’s List of Registered Foreign Charities Down to Zero

The Canada Revenue Agency’s list of foreign charitable organizations that are treated the same as Canadian charities for tax purposes has now been reduced to zero, making it that much more difficult to garner financial support for international causes. …

Prepared by: E. Rebecca Potter

Becky Potter is a partner practicing in the firm’s Toronto office. Known for her strategic approach, honed advocacy skills, and breadth of tax knowledge, Becky Potter is a highly sought-after tax litigator. She has successfully represented her clients at every… more »

Share

Tax Court of Canada Releases Decision Regarding Medical Expenses Claimed for a Surrogacy Arrangement

In Warnock v. The Queen, 2014 TCC 240, the Tax Court of Canada considered medical expense tax credits claimed by the taxpayer for various expenses incurred with respect to a surrogacy arrangement.

Prepared by: Shawn Tryon

Shawn is a partner practicing in the firm’s Vancouver office. His practice focuses on both tax planning for individuals and businesses as well as audit representation and tax litigation matters. On audit representation and tax litigation matters, Shawn has extensive… more »

Share