“the new procedures should provide some relief.” On June 26, 2012, the IRS announced new “catch up”…

“It is also important to consider the various attribution rules that could apply.” Generally, the Income Tax…

“most countries have legislation permitting the enforcement of foreign judgments.” Can the Canada Revenue Agency (“CRA”)  “get…

“These new rules should generally provide greater flexibility.” Since the introduction of the eligible dividend rules in…

“In a typical family estate freeze, this anti-avoidance rule will not likely apply.” Some business owners may…

“The ‘prohibited investment’ rules… have significantly impacted RRSP and RRIF holdings of private company shares.” Shares of…

“The type of investor can also impact whether an ABIL is available.” An Allowable Business Investment Loss…

“Post Mortem Pipeline Transactions.” As discussed in Tax Tip 10-13, post-mortem tax planning is important for a deceased…

“Residence of Trusts.” The Supreme Court of Canada recently confirmed the decisions of two lower courts and…

“There are two changes in this revised version of T5013 that are worth noting..” New Disclosure Requirements…