Year-End Tax Planning for Tax-Free Savings Accounts: Top TFSA Moves You Should Make Before the End of 2024

The 2024 taxation year is almost done, and it's time to take advantage of year-end…

Published: November 20, 2024

Last Updated: November 20, 2024

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Consequences of Failure to File Valid Business Limit Allocation Agreement with CRA and Missing Out on the Small Business Deduction

Introduction - The Business Limit Allocation Among Associated CCPCs A Canadian-controlled private corporation (CCPC) is…

Published: November 14, 2024

Last Updated: November 14, 2024

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Case Commentary: Onex Corporation v. Canada, 2024 FC 1247 –subsections 220(2.1) and 220(3) of the Income Tax Act Can Grant Relief from Tax Reassessment, Plus Filing Requirements

In August 2024, the Federal Court ("FC") delivered its judgment on Onex Corporation v. Canada,…

Published: November 6, 2024

Last Updated: November 6, 2024

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Beware CRA’s Ability to Share Information with Foreign Tax Authorities Using Tax Information-Exchange Provision In Bilateral Tax Treaties And Tax Information Exchange Agreements: A Canadian Tax Lawyer’s Primer

Introduction: CRA Has the Ability to Exchange Tax-related Information with Foreign Taxing Authorities, Subject to…

Published: November 5, 2024

Last Updated: November 5, 2024

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Canadian Tax Traps for Professional Athletes Entering, Leaving, or Playing in Canada: Tax-Planning Considerations for Cross-Border Professional Athletes

Introduction: Canadian Tax Planning for Professional Athletes For professional athletes, life off the field or…

Published: November 4, 2024

Last Updated: November 4, 2024

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Can CRA Collect Tax on Your Foreign Assets? Yes, Tax Collection Assistance Provisions Exist Between Canada and other Countries, Canadian Tax Lawyer Explains

Introduction: The Collection-Assistance Provision in Tax Treaties Between Canada And Other Countries As the world…

Published: October 28, 2024

Last Updated: October 28, 2024

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Case Commentary: Glencore v. Canada – How are Commitment Fees and Break Fees in M&A Transactions taxed? Windfall or Business Income?

Introduction - Commitment Fee and Break Fee in M&A transactions In March 2024, the Supreme…

Published: October 25, 2024

Last Updated: November 4, 2024

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New Digital Services Tax to Impose 3 per cent Tax on Multinational Digital Firms with $20M in Canadian Revenue; Prepare now, says Expert Canadian Tax Lawyer

The Canadian Federal Government has enacted a controversial Digital Services Tax that will bring in…

Published: October 21, 2024

Last Updated: October 21, 2024

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Case Commentary: When Can Directors, Employees, Independent Contractors Claim the Small Business Deduction? – Astro Consulting Inc. v R.

Introduction – Director’s corporation claiming small business deduction In August 2024, the Supreme Court of…

Published: October 15, 2024

Last Updated: October 10, 2024

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