Professional Incorporation Update

“Holding companies cannot be used to hold shares of a professional corporation.” Further to the recent Tax…

Fairness & Late Filing Penalties

“Late-filing penalties were referred back to CRA because all taxes were paid.” In the recent case of Bremer (2006…

Stock Option Deductions

“Payments to an employment consultant are not permissible deductions from stock options.” The case of Morin (2006FCA 25) is…

GAAR – Using Attribution to the Taxpayer’s Benefit

“Using attribution to your benefit is not GAAR.” In the recent case of Overs (2006 TCC 26), the taxpayer’s…

Due Date of Corporate Taxes

“The due date of corporate taxes depends on many factors.” There is a misconception about when corporate…

Professional Incorporation – Doctors’ & Dentists’ Family Members

“There are new changes to the OBCA allowing family members to be non-voting shareholders.” On December 22,…

Allowable Business Investment Losses – Payments to Individuals in Trust for Companies

“Payments to individuals on behalf of companies may still be ABIL.” In the case of Brand (2005…

Capital Dividend Account (CDA) and Eligible Capital Expenditures (ECE) – Beware

“CDA payments related to ECE cannot be paid until the next taxation year.” Dispositions of Eligible Capital…

Withholding Tax Rates to Non-Resident Trusts & Their Beneficiaries

“The CRA has revised their policy on payments to non-resident trusts.” In 1987, the CRA issued a…

First GAAR Case After Supreme Court Decision

“The Evans case clarifies the practical application of GAAR.” A recent case (Evans) decided by Chief Justice Bowman of…

Cadesky Tax Books

STEP CANADA/CRA Roundtables

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Trusts and International Tax Treaties

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Taxation of Real Estate in Canada

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Towards Greater Fairness in Taxation: A Model Taxpayer Charter

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Taxation of Trusts and Estates: A Practitioner’s Guide 2024

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Taxation at Death: A Practitioner’s Guide, 2021

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