Tax Trends
U.S. Companies Investing in Canada
“Be aware of using U.S. LLC’s to hold shares in Canadian companies.” U.S. companies frequently consider carrying…
Stock Option Deferral – Cost Base Calculations
“Detailed records are necessary to calculate the cost base of stock option deferral shares.” A few years…
Employees Profit Sharing Plans
“EPSP’s do not work in all situations.” There have been a number of recent publications stating that…
SR&ED Claim for Stock Option Benefit
“Stock option benefit can be used for ITC calculation.” The CRA has recently issued a bulletin accepting…
When a Hotel Is Not a Lodge – 18(l)
“The CRA lost their argument that country hotels are lodges.” A recent case looked at whether payments…
Analysis of “Arm’s Length”
“CRA lost in its approach that any transactions that reduce taxes must be between non-arm’s length taxpayers.”…
Residency Test – Allchin Revisited
“Tax Court forced to take a second look at this case.” The Federal Court of Appeal concluded…
Alberta Unlimited Liability Company (“ABULC”)
“ABULC’s are cost-effective alternatives to NSULC’s.” Until May 2005, US investors in Canada could only use a…
Federal Court Makes Decision on Voluntary Disclosures
“No-names basis submission that was accepted by CRA cannot be disregarded by CRA afterwards if facts have…
Salaries & Bonuses To Family Members
“In-kind payments are acceptable and so are large bonuses to non-shareholder family members..” Two fairly recent cases…
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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