“The penalty could apply on a per-item basis.” Over the last few years, the U.S. has significantly…

“”the combined tax bill can be significantly lower than the tax on the salary would be”.” It…

“If Mr. X had retained and sold the investment, there would be no tax liability.” Potential unintended…

“Loans to non-residents can cause income inclusions.” Subsection 17(1) of the Income Tax Act (“Act”) is a…

“This withholding tax requirement is often overlooked.” In a recent technical interpretation (2009-0345151E5), the Canada Revenue Agency…

“Early identification and good documentation are critical.” The Scientific Research and Experimental Development (SR&ED) tax credit program…

“U.S. status could eliminate many Canadian tax benefits.” Canada taxes individuals on their worldwide income only if…

“Using an RRSP as security for a loan may be a better alternative than cashing in the…

“Two deductions may be available to individuals.” Two deductions may be available to individuals employed as tradespersons…

“The decision whether to elect out of the spousal rollover can be made on a share-by-share basis.”…