Large Corporations Tax Issue

“Un-presented cheques should not be included in taxable capital..” In the recent case of Canadian Forest Products…

Single Purpose Corporations – New Proposals

“CRA has issued a new administrative policy on single purpose corporations that own US property..” In the…

CRA Disputes

“Information available for a notice of objection..” Whenever a taxpayer or his/her representative is dealing with the…

Allowable Business Investment Losses

“Issues To Consider.” A business investment loss (BIL) arises from a disposition to which subsection 50(1) applies…

Fairness Rules – December 2004 Deadline

“All files should be checked..” Generally speaking, the Fairness Rules allow the Canada Revenue Agency discretion to…

Residency Test

“Tax treaties should be considered in determining whether an individual is resident in Canada..” In a recent…

Deductibility of Management Bonus

“Be aware of CRA policy on deductibility of management bonuses..” CRA tried to clarify its position on…

Withholding Tax For Services Done – By Non-Residents in Canada

“A 15% withholding tax may be payable for services rendered in Canada..” Regulation 105 states that every…

Deemed Association

“Shares held by trusts or minors could have adverse results for association purposes..” There are a number…

Attribution That Works

“Low Prescribed Rates Allow for Income Splitting.” The third quarter of prescribed rate has been set at…

Cadesky Tax Books

STEP CANADA/CRA Roundtables

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Trusts and International Tax Treaties

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Taxation of Real Estate in Canada

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Towards Greater Fairness in Taxation: A Model Taxpayer Charter

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Taxation of Trusts and Estates: A Practitioner’s Guide 2024

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Taxation at Death: A Practitioner’s Guide, 2021

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