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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How the Income Tax Act Treats Settlements and Damage Awards for Wrongful Dismissals

General Principle – Income Must Come From a Source The general principle under the Income…

Published: July 9, 2025

Last Updated: July 9, 2025

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How are Professional Poker Winnings Taxed in Canada? Taxable Business Income and Non-Taxable Hobbies: Fournier-Giguère v. Canada et. al., 2025 FCA 112

Introduction: Taxability of Poker Winnings – The Difference Between Non-Taxable Hobbies and Taxable Business Income…

Published: July 4, 2025

Last Updated: July 4, 2025

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A Canadian Tax Lawyer’s Guide to Changes in Tax Obligations for Trust Executors and Trustees that will Simplify Estate Administration

Proposed amendments to the Income Tax Act (ITA)will ease the administrative burdens of executors and…

Published: June 26, 2025

Last Updated: June 26, 2025

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A Canadian Tax Lawyer’s Guide to s.51 Rollovers: What and How Shareholders Can Convert Equity into New Shares Without Capital Gains

Introduction: S.51 rollovers S.51 rollovers are one of the many tax-free rollovers the Income Tax…

Published: June 26, 2025

Last Updated: June 26, 2025

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