Canadian Tax Trap: Section 160 Leads to Derivative Tax Liability for 50-50 Shareholders Who Receive Dividends from a Tax-Debtor Corporation: McCague v The King, 2025 TCC 59

Introduction – Derivative Tax Liability under Section 160 of Canada’s Income Tax Act & Dividends…

Published: August 19, 2025

Last Updated: August 19, 2025

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A Canadian Tax Lawyer’s Tax Guide For ‘Digital Nomads’ Moving to Canada: What You Need to Know About Canada’s Tax System

Introduction: Who is a Digital Nomad? A digital nomad is someone who earns income through…

Published: August 19, 2025

Last Updated: August 19, 2025

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A Canadian Tax Lawyer’s Case Commentary on Magren Holdings Ltd. v Canada, 2024 FCA 202: The Application of General Anti-Avoidance Rule (GAAR) on Capital Dividends

What is the General Anti-Avoidance Rule (GAAR) in the Canadian Income Tax Act? The General…

Published: August 6, 2025

Last Updated: August 6, 2025

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Blecha v the King – What Expenses Can Owners Deduct from Rental Properties That Produce No Income?

Introduction: CRA's Reassessments Related to Deductibility of Expenses for a Rental Property   Blecha v…

Published: July 31, 2025

Last Updated: July 31, 2025

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The CRA issues a new ‘Income Tax Folio’ on How Shareholder Loans and Debts are Treated

Income Tax Folio S3-F1-C1 Shareholder Loans and Debts replaces and cancels Interpretation Bulletin IT-119R4 In…

Published: July 28, 2025

Last Updated: August 18, 2025

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When Can Businesses Deduct Interest Payments? A Primer from a Canadian Tax Lawyer

The Income Tax Act has rules that allow the deduction of interest in specific situations.…

Published: July 25, 2025

Last Updated: July 25, 2025

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When full business income tax, other than capital gains tax, is payable if business activities are based on a “secondary intention” tax law doctrine in an “adventure in the nature of trade” – guidance from a Canadian tax lawyer

The tax treatment of income in Canada depends on its classification, making it essential for…

Published: July 25, 2025

Last Updated: July 25, 2025

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Cancelling Canada’s Digital Services Tax Creates Immediate Logistical Problems at CRA; Don’t Expect a Refund Soon if You Have Pre-Paid

Introduction: What is the Digital Services Tax in Canada? Why Did Canada Cancel the DST?…

Published: July 23, 2025

Last Updated: July 23, 2025

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How CRA Conducts Net Worth Audits and Enforces Gross Negligence Penalties Against Canadian Taxpayers: Lessons from Mann v. The King and Other Cases

Introduction - Net Worth Audits Before the Tax Court: What Taxpayers Should Know In Mann…

Published: July 10, 2025

Last Updated: July 10, 2025

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