Tax Trends
Wind-Up vs. Amalgamation: A Big Difference
“Whether an amalgamation or a wind-up is chosen, the tax consequences may be unintentionally different.” Wind-ups and…
Foreign Operations & The Capital Gains Exemption
“Shares of foreign corporations may render a corporation ineligible for the capital gains exemption.” Most people are…
Fifth Protocol – Canada-U.S. Tax Treaty – Stock Options
“The revised Protocol provides a mechanism for allocating stock option income between the countries.” In annex B…
Leasehold Inducements
“Tax treatment does not automatically follow the accounting treatment for leasehold inducements.” For accounting purposes, a leasehold…
Attribution of Property on Marital Breakdown
“Filing the appropriate elections is necessary to ensure that an unexpected result does not occur.” As discussed…
Transfer of Properties on Separation & Divorce
“Proper planning can result in benefits to both sides.” When properties are transferred between related persons, the…
When CRA Does Not Like the Results, GAAR Is Applied
“The CRA will use GAAR to overcome a decision they do not like.” The recent case of McMullen…
Be Careful if You Allocate Partnership Income Only to Reduce Tax
“The CRA can reallocate partnership income allocations when they consider the allocations tax motivated.” In the recent…
Transit Pass Credit & Fitness Tax Credit
“The transit pass credit is for 2006 and the fitness tax credit is for 2007.” There seems…
Separate Class for Rental Buildings
“The allocation of purchase price is important on the purchase of rental properties.” When a rental building…
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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