Tax Alert Archives

CRA Releases Statistics on Offshore Tax Informant Program

CRA released statistical information regarding its Offshore Tax Informant Program (OTIP). Since its launch on January 15, 2014, the OTIP allows the CRA to make financial awards to individuals who provide information related to major international tax-non-compliance. The details of…

Prepared by: Ken Jiang

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 »

Share

CRA Requires Taxpayers to Provide Support for U.S. Foreign Tax Credits

At the 2016 STEP Round Table, the CRA noted that since 2015, taxpayers are required to provide supporting documents for claims of U.S. foreign tax credits. The same requirement has always applied to all countries other than the U.S. The…

Prepared by: Ken Jiang

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 »

Share

Filing Deadline for self-employed Individuals is June 15, 2016

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…

Prepared by: Ian Humphries

Ian Humphries is an Associate 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 »

Share

The Supreme Court of Canada strikes down “accounting records” exception to solicitor-client privilege

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…

Prepared by: Ian Humphries

Ian Humphries is an Associate 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 »

Share

CRA considers that the ACB grind under subsection 84.1(2.1) applies notwithstanding a taxpayer’s intention not to claim a capital gains exemption

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…

Prepared by: Florence Sauve

Florence Sauve is a partner in the Toronto office of Thorsteinssons LLP. Florence’s practice focuses on all aspects of taxpayer representation and tax litigation and also includes personal and corporate tax planning.  She assists her clients in managing and resolving… more »

Share

CRA confirms deductibility of interest on funds borrowed to finance share repurchase under “fill-the-hole” theory

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.…

Prepared by: Florence Sauve

Florence Sauve is a partner in the Toronto office of Thorsteinssons LLP. Florence’s practice focuses on all aspects of taxpayer representation and tax litigation and also includes personal and corporate tax planning.  She assists her clients in managing and resolving… more »

Share