“Complicated rules for a simple situation.” When an individual moves from one city to another, the issue…

“Sale of sole proprietor can be tax-free with planning.” The first $750,000 of the capital gain on…

“Whether an amalgamation or a wind-up is chosen, the tax consequences may be unintentionally different.” Wind-ups and…

“Shares of foreign corporations may render a corporation ineligible for the capital gains exemption.” Most people are…

“The revised Protocol provides a mechanism for allocating stock option income between the countries.” In annex B…

“Tax treatment does not automatically follow the accounting treatment for leasehold inducements.” For accounting purposes, a leasehold…

“Filing the appropriate elections is necessary to ensure that an unexpected result does not occur.” As discussed…

“Proper planning can result in benefits to both sides.” When properties are transferred between related persons, the…

“The CRA will use GAAR to overcome a decision they do not like.” The recent case of McMullen…

“The CRA can reallocate partnership income allocations when they consider the allocations tax motivated.” In the recent…