Tax Trends
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…
New Dividend Rates
“The new dividend tax rates will affect owner/manager clients.” On November 23, 2005, the Minister of Finance…
SR&ED/Stock Option #2
“Proposed Amendments to deny stock option benefit in ITC calculation.” In a previous Tax Tip (05-22), it…
Fairness Provisions
“If CRA does not consider all facts, the courts are willing to reverse their decisions.” In the…
Association – Control in Fact
“Control in fact must be determined by considering all relevant factors.” In the case of Timco Holdings Limited…
When is an Amount Paid in Order to Be a Deduction?
“Can a taxpayer deduct an amount he didn’t pay directly?.” In the case of Williams (2004 DTC 3549), the…
Change of Control – Trustees
“A change of trustees could result in a change of control.” The CRA recently issued Technical Interpretation…
CCA & Beneficial Ownership
“Ownership by a spouse does not preclude CCA and related expenses if paid by the taxpayer.” A…
Voluntary Disclosure – On a No-Name Basis
“There is a 90-day limit to disclose the taxpayer’s name.” The CRA recently clarified its policy on…
Cadesky Tax Books
STEP CANADA/CRA Roundtables
Trusts and International Tax Treaties
Taxation of Real Estate in Canada
Towards Greater Fairness in Taxation: A Model Taxpayer Charter
Taxation of Trusts and Estates: A Practitioner’s Guide 2024
Taxation at Death: A Practitioner’s Guide, 2021
Cadesky Tax Firm Brochure
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