Tax Alert Archives

CRA indicates that deduction of foreign non-business tax paid by partnership is available to indirect individual member

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…

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 »

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CRA confirms deductibility of professional fees incurred to defend taxpayer’s position after acceptance of voluntary disclosure

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…

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 »

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The deadline for individuals to file their 2015 tax returns is May 2, 2016

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

Prepared by: Jennifer Flood

Jennifer Flood is an associate practicing in the firm’s Vancouver office. Jennifer’s practice focuses on taxpayer representation and tax litigation, including both civil and criminal matters. She advises and represents clients in the course of tax audits, appeals, criminal investigations,… more »

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Notice of Ways and Means Motion tabled by Minister of Finance

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…

Prepared by: Jennifer Flood

Jennifer Flood is an associate practicing in the firm’s Vancouver office. Jennifer’s practice focuses on taxpayer representation and tax litigation, including both civil and criminal matters. She advises and represents clients in the course of tax audits, appeals, criminal investigations,… more »

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Minister of National Revenue gives press conference on new offshore initiatives

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…

Prepared by: Jennifer Flood

Jennifer Flood is an associate practicing in the firm’s Vancouver office. Jennifer’s practice focuses on taxpayer representation and tax litigation, including both civil and criminal matters. She advises and represents clients in the course of tax audits, appeals, criminal investigations,… more »

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Crown says follow-up questions arising from answers to undertakings must be posed orally

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…

Prepared by: Jennifer Flood

Jennifer Flood is an associate practicing in the firm’s Vancouver office. Jennifer’s practice focuses on taxpayer representation and tax litigation, including both civil and criminal matters. She advises and represents clients in the course of tax audits, appeals, criminal investigations,… more »

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Dissolved corporation may not initiate a Tax Court appeal

In 1455257 Ontario Inc. v. Canada, 2016 FCA 100, the Federal Court of Appeal held that a dissolved Ontario corporation lacks the capacity to appeal from an assessment in the Tax Court of Canada because the Ontario Business Corporations

Prepared by: Jennifer Flood

Jennifer Flood is an associate practicing in the firm’s Vancouver office. Jennifer’s practice focuses on taxpayer representation and tax litigation, including both civil and criminal matters. She advises and represents clients in the course of tax audits, appeals, criminal investigations,… more »

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CRA Updates and Replaces Information Circular on Clearance Certificates

The CRA has published Information Circular (IC82-6R11), which contains information pertaining to applications for clearance certificates in respect of subsection 159(2) of the Income Tax Act (Canada).  New IC82-611 cancels and replaces its predecessor IC82-6R10 dated November 25, 2013.

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 »

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CRA modifies Income Tax Folio S3-F6-C1, Interest Deductibility

Income Tax Folio S3-F6-C1, which contains the CRA’s position on interest deductibility, has been modified in respect of deductibility under subparagraph 20(1)(c)(ii) of the Income Tax Act (Canada) in the context of substituted property.

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 »

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Government of British Columbia Publishes Fact Sheet: “Competitive Business Taxes Support British Columbia Economy”

The Ministry of Finance, British Columbia, has published a fact sheet pertaining to corporate and small business income taxation in British Columbia.

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 »

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