Tax Trends
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…
Stock Option Deferral – Cost Base Calculations
“Detailed records are necessary to calculate the cost base of stock option deferral shares.” A few years…
Employees Profit Sharing Plans
“EPSP’s do not work in all situations.” There have been a number of recent publications stating that…
SR&ED Claim for Stock Option Benefit
“Stock option benefit can be used for ITC calculation.” The CRA has recently issued a bulletin accepting…
When a Hotel Is Not a Lodge – 18(l)
“The CRA lost their argument that country hotels are lodges.” A recent case looked at whether payments…
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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