Butterfly Reorganization Leading to Third-Party Tax Liability

Introduction - Eyeball Networks Inc. v the Queen and Butterfly Reorganization A butterfly reorganization is…

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Retirement Compensation Arrangement: Canadian Tax Lawyer Guide

How does a Retirement Compensation Arrangement work and what are the benefits? – tax guidance…

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Tax Risks from Underground Banks: Toronto Tax Lawyer Analysis

Introduction – Underground Banks and Hawalas Canada has been criticized for failing to police and…

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Guidance on Arbitrary Tax Assessments and Derivative Tax Liability

What is an Arbitrary Tax Assessment? When a taxpayer fails to file a tax return…

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Taxation of Cryptocurrency Liquidity Mining & Yield Farming

Introduction – What Is Cryptocurrency Liquidity Mining (or Yield Farming)? When you deposit money in…

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Self-Employed May Not Repay CERB: Canadian Tax Lawyer Guide

Introduction - Self-Employed Canadians May Not Have to Repay the Canada Emergency Response Benefit &…

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Relief for Employee Remittance for Undue Hardship to Employer

Taxpayer relief provisions When a taxpayer fails to comply with his obligations under the Income…

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Residence Determinations: Canadian Tax Lawyer’s Guide

What is Canadian Tax Residence? There are two types of residence for taxpayers; their immigration…

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CERB Repayment: Do This to Avoid the CRA’s December 31st Payback Demand

The CRA wants its CERB money back. And it wants it no later than December…

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