Taxation of Shareholders: The Basic Deemed-Dividend Tax Rules—A Canadian Tax Lawyer’s Analysis

Introduction – The What And Why of a Deemed Dividend What is a deemed dividend?…

Published: April 30, 2020

Last Updated: February 21, 2022

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The Tax Court of Canada Tests a New Procedure – The Preliminary Ruling Docket: Canadian Tax Lawyer Analysis

Introduction: Tax Court Deals with Increasing Backlog With the rise of the internet and the…

Published: April 30, 2020

Last Updated: July 17, 2020

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Deadlines for Notice of Objections, Notice of Appeals, and Extension of Times – Canadian Tax Lawyer Explains

Tax Notices of Objection, Deadlines and Applying for Extensions Upon receiving a Notice of Assessment…

Published: April 30, 2020

Last Updated: April 26, 2021

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CHR Investment Corporation v The Queen – GAAR – (Subsection 245(2)) of the Income Tax Act and the Need for Clarify on Policy Application and Analysis

The Legal Background & Section 245’s GAAR Policies The general anti-avoidance rule (“GAAR”) is found…

Published: April 30, 2020

Last Updated: October 25, 2021

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A Canadian Tax Lawyer’s Introduction to Tax Filing for International Students

Welcome to Canada’s Tax System Tax season can be especially confusing for international students who…

Published: April 30, 2020

Last Updated: October 21, 2022

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Canadian Tax Lawyer Analysis of Gurpal Saini v. Her Majesty the Queen: Challenging the Net-Worth Method of Assessment

Introduction: The Net-Worth Method of Assessment One of the most fundamental rules of the Income…

Published: April 30, 2020

Last Updated: October 25, 2021

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Equity Deadline and when the CRA is at Fault

Introduction – Fairness and when CRA is at fault As a complex and massive administrative…

Published: April 30, 2020

Last Updated: October 25, 2021

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Donation Tax Shelter, Roher v. the Queen

Introduction – Buy Low, Sell High Donation Arrangement and the Issue of Roher v the…

Published: April 28, 2020

Last Updated: May 20, 2020

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Canada-Israel Income Tax Convention & the Making of Aliyah from Canada to Israel – Canadian Tax Lawyer Analysis

Introduction - What is Aliyah? Aliyah is the emigration of the Jewish people and their…

Published: April 28, 2020

Last Updated: October 25, 2021

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