Tax Trends
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…
Change of Control – Trustees
“A change of trustees could result in a change of control.” The CRA recently issued Technical Interpretation…
CCA & Beneficial Ownership
“Ownership by a spouse does not preclude CCA and related expenses if paid by the taxpayer.” A…
Voluntary Disclosure – On a No-Name Basis
“There is a 90-day limit to disclose the taxpayer’s name.” The CRA recently clarified its policy on…
U.S. Companies Investing in Canada
“Be aware of using U.S. LLC’s to hold shares in Canadian companies.” U.S. companies frequently consider carrying…
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
Cadesky Tax Firm Brochure
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