Deemed Association
“Shares held by trusts or minors could have adverse results for association purposes..” There are a number…
Attribution That Works
“Low Prescribed Rates Allow for Income Splitting.” The third quarter of prescribed rate has been set at…
Evidence Required
“Sometimes evidence accepted by Courts is different from the CRA..” A situation that many professionals face when…
Personal Health Service Plans and Shareholder Benefits
“There could be shareholder benefits and non-deductible payments for PHSP’s..” In a recent case (Spicy Sports Inc.),…
Disassociating Companies
“Using a specified class of shares can disassociate companies..” There are many situations where two companies are…
Foreign Social Security Taxes As Foreign Tax Credits
“For countries other than U.S., the foreign social security taxes are no longer a tax credit..” The…
Single Purpose Corporations
“CRA has changed its administrative position for companies owning U.S. real estate..” In a recent Technical News,…
Loans To Family Members
“Certain conditions are necessary to claim capital losses on loans to family members..” There have been a…
Overpayment of U.S. Taxes May Prohibit Claim of Foreign Tax Credit
“Taxpayers must ensure that they only pay the withholding rate per the treaty.” In a recent tax…
Supreme Court Decision – Gifford
“This Supreme Court case is relevant for the purchase of intangible assets and interest deductibility.” On February…
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
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