Case Commentary: Fijal v. The King, 2024 TCC 116 – Why Proper Bookkeeping is the Best Protection for Businesses When They’re Reassessed by the CRA

In September 2024, the Tax Court of Canada delivered its judgment on Fijal v. The…

Published: December 11, 2024

Last Updated: December 11, 2024

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What Are a Taxpayer’s Rights During an Access to Information and Privacy (ATIP) Request for Their Own Tax Records? Canadian Tax Lawyer Explains

Introduction: An ATIP Request Helps Taxpayers to Obtain Government Records Concerning Their Tax Matters. An…

Published: November 28, 2024

Last Updated: November 28, 2024

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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: March 5, 2025

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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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