Tax Trends
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…
Evidence Required
“Sometimes evidence accepted by Courts is different from the CRA..” A situation that many professionals face when…
Personal Health Service Plans and Shareholder Benefits
“There could be shareholder benefits and non-deductible payments for PHSP’s..” In a recent case (Spicy Sports Inc.),…
Disassociating Companies
“Using a specified class of shares can disassociate companies..” There are many situations where two companies are…
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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