Tax Trends
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…
Analysis of “Arm’s Length”
“CRA lost in its approach that any transactions that reduce taxes must be between non-arm’s length taxpayers.”…
Residency Test – Allchin Revisited
“Tax Court forced to take a second look at this case.” The Federal Court of Appeal concluded…
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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