Taxation
Practice
Selling a business to an employee ownership trust: the tax memo can be right and the deal can still fail
The $10-million capital gains exemption is permanent. Your client's control over the company it applies to ends the afternoon he signs, explains Koby Smutylo
- COMMENTS 13
- LIKES 149
- VIEWS 160
Practice
The salary-dividend decision after the small business rate cut
In part two of his two-part series, Bashar Qawas of Better Books Canada delves deeper into the unevenness of small business rate cuts in Ontario and Quebec
- COMMENTS 13
- LIKES 149
- VIEWS 160
Business
A short history of welcome mats: How Alberta courted two types of newcomers on the grounds of demand and economic impact
Will Alberta’s tradeoff of tax breaks for tax revenue for AI data centres end like the Alberta is Calling campaign — far too successful for its well-being?
- COMMENTS 13
- LIKES 149
- VIEWS 160
Practice
Philanthropists critical of Nakba exhibit donated $4.8M to groups later sanctioned
Canada Revenue Agency has revoked tax status of many Canadian charitable organizations academic asserts are “largely just conduits” for overseas funding
- COMMENTS 13
- LIKES 149
- VIEWS 160
Practice
The small business rate cut that partly reverses in January
In part one of a two-part series, Bashar Qawas of Better Books Canada explains the timing mismatch in cuts to the small business corporate income tax rate
- COMMENTS 13
- LIKES 149
- VIEWS 160
Practice
Federal Court sets strict Mutual Agreement Procedure (MAP) deadline in reassessment deals with Canada Revenue Agency
The FC Robinson MAP deadline ruling has implications for cross-border taxpayers, owner-managers, corporate groups, and accountants, says David J Rotfleisch
- COMMENTS 13
- LIKES 149
- VIEWS 160
Practice
ExxonMobil Canada Resources Company v. the King, case study
Lorne Saltman of Gardiner Roberts LLP explains why the Tax Court rejected the CRA’s position that a $36-million pipeline feasability study was not deductible
- COMMENTS 13
- LIKES 149
- VIEWS 160
Practice
Notice of Assessment was never mailed? Federal Court of Appeal clarifies taxpayer must first prove non-delivery
The FCA Siam decision reinforces that taxpayers bear the burden of proving that a Notice of Assessment was not sent, and credibility plays a central role
- COMMENTS 13
- LIKES 149
- VIEWS 160
Practice
Complaints about CRA rise 27% despite recent automated tax filing, call centre failures, processing delays, poor communication
Canada’s tax act is completely nuts; administrative modernization cannot succeed without legislative simplification, asserts tax lawyer David J Rotfleisch
- COMMENTS 13
- LIKES 149
- VIEWS 160
Practice
Why R v Jarvis is the most important tax case for Canadian taxpayers
The 2002 Supreme Court of Canada decision presents a clear line between a CRA tax audit versus a criminal tax investigation, explains David J Rotfleisch
- COMMENTS 13
- LIKES 149
- VIEWS 160
Practice
Tax Court confirms that taxpayers must provide clear instructions to apply refund balances
A recent Tax Court decision in BMLex Avocats v The King explains why a tax credit balance does not protect taxpayer from GST/HST instalment interest
- COMMENTS 13
- LIKES 149
- VIEWS 160
Thought Leaders
The OAS clawback is due for reform – but not the reform you may think
The Old Age Security Recovery Tax is not based on a pure measure of economic capacity and should be replaced with a smarter measure of economic capacity
- COMMENTS 13
- LIKES 149
- VIEWS 160
