Change to Post Mortem Planning

“sometimes traditional planning techniques become outdated.” As we alluded to in Tax Tip 10-11, sometimes traditional planning techniques…

Expanded Reporting Requirement For Foreign Assets

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

Personal Service Businesses

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

Stock Option Tax Deferral Election

“The 2010 Federal Budget proposes to repeal the employee stock option tax deferral election.” Employee stock options…

Transfers of Investments to Corporations

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

Subsection 17(1) Income Inclusions

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

Directors’ Fees Paid to Non-Residents

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

Scientific Research & Experimental Development

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

Severe Penalties for Not Reporting Foreign Property

“Form T1135 includes a certificate of full disclosure to be signed by the taxpayer.” The current T1…

U.S. Citizens in Canada

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

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