U.S. Profits Interests: What Are They & How Are They Taxed in Canada?—A Canadian Tax Lawyer’s Analysis
Introduction – U.S. Profits Interests For U.S. federal income-tax purposes,…
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Capital-Gains Implications of Gifts & Other Non-Arm’s-Length Transactions Deviating from Market Value: Subsection 69(1) of Canada’s Income Tax Act – A Canadian Tax Lawyer’s Analysis
Introduction – Taxation of Capital Gains in Canada Generally, when…
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Saving Taxes: Elections are a Great Tool – A Canadian Tax Lawyer Analysis
Introduction: Tax Elections Offer Option and Flexibility to Taxpayers Canadian…
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Double Derivative Tax Liability: How Does Derivate Tax Liability under Section 160 Interact with Derivative Tax Liability of a Director under Section 227.1? Colitto v The Queen (2019 TCC 88) – A Canadian Tax Lawyer’s Analysis
Introduction: Inheriting the Tax Liability of Another Taxpayer Canada’s Income Tax…
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Upcoming Changes to the Voluntary Disclosures Program (VDP) – A Canadian Tax Lawyer Analysis
On December 15, 2017 the Canada Revenue Agency published Information…
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