Tax Trends
Professional Incorporation – Doctors’ & Dentists’ Family Members
“There are new changes to the OBCA allowing family members to be non-voting shareholders.” On December 22,…
Allowable Business Investment Losses – Payments to Individuals in Trust for Companies
“Payments to individuals on behalf of companies may still be ABIL.” In the case of Brand (2005…
Capital Dividend Account (CDA) and Eligible Capital Expenditures (ECE) – Beware
“CDA payments related to ECE cannot be paid until the next taxation year.” Dispositions of Eligible Capital…
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…
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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