Leasehold Inducements

“Tax treatment does not automatically follow the accounting treatment for leasehold inducements.” For accounting purposes, a leasehold…

Attribution of Property on Marital Breakdown

“Filing the appropriate elections is necessary to ensure that an unexpected result does not occur.” As discussed…

Transfer of Properties on Separation & Divorce

“Proper planning can result in benefits to both sides.” When properties are transferred between related persons, the…

GAAR – Reasons For Transaction

“Having a business transaction may preclude GAAR when tax is not the main motivation.” In the recent…

New CRA Receipt Policy Worrisome To SR&ED Filers

“File early to allow CRA enough time to confirm all information has been provided.” CRA has recently…

When CRA Does Not Like the Results, GAAR Is Applied

“The CRA will use GAAR to overcome a decision they do not like.” The recent case of McMullen…

Be Careful if You Allocate Partnership Income Only to Reduce Tax

“The CRA can reallocate partnership income allocations when they consider the allocations tax motivated.” In the recent…

Transit Pass Credit & Fitness Tax Credit

“The transit pass credit is for 2006 and the fitness tax credit is for 2007.” There seems…

Separate Class for Rental Buildings

“The allocation of purchase price is important on the purchase of rental properties.” When a rental building…

Attribution Rules – Spousal Loans

“Attribution can be avoided on spousal loans in certain situations.” When an individual loans funds to a…

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