Taxable Canadian Property (TCP) & Section 116 Taxable Canadian Property refers to specific types of Canadian assets that, when sold or transferred by a non-resident of Canada, may trigger Canadian tax obligations. Section 116 of the Income Tax Act (R.S.C., 1985,
Subsection 164(1) – Refunds or Credits on Overpayment of Taxes Subsection 164(1) of the Income Tax Act (R.S.C., 1985, c. 1 (5th Supp.)) primarily deals with the refund or credit of taxes paid in excess. Specifically, it governs how the
March 21, 2025 Government Announcement re: GST/HST and Corporate Tax Relief for Businesses Canada Revenue Agency (CRA) is implementing relief from GST/HST and corporate tax remittances for approximately 3 months. According to the government’s announcement businesses can “[d]efer corporate income tax payments
Understanding Trust Amounts and CRA Collections When running a business, understanding your responsibilities around trust amounts and how the Canada Revenue Agency (CRA) handles collections is crucial. Failing to manage these obligations properly can lead to audits, penalties, and aggressive
Tiered Partnerships & Flow-Through Characteristics A tiered or stacked partnership refers to a partnership that owns a partnership interest in another partnership. The Tax Court of Canada (TCC) affirmed the flow-through characteristics of income and losses through a tiered partnership structure
Admissibility of Expert Evidence in Tax Court As outlined in the decision of the Tax Court of Canada in Cambridge Leasing Ltd. v. The King, 2024 TCC 136, determining the admissibility of expert evidence is a two-stage process: Threshold admissibility:
Pleading Relevant Facts Parties must plead relevant facts. The issue of relevant facts was addressed in the Tax Court of Canada (“TCC”) decision of Basal v. The King, 2022 TCC 154[Basal], which involved potential director liability for specific corporate tax
Zero-Rated Supplies & GST/HST The Goods and Services Tax (GST) and Harmonized Sales Tax (HST) are consumption-based taxes levied in Canada. These taxes are applied to the sale of most goods and services. However, not all supplies are taxed at
Understanding Tax Treaties: The Basics and Importance Tax treaties play a pivotal role in the global tax system. They are bilateral agreements between two countries designed to avoid double taxation on income and capital, as well as to prevent tax evasion.
Overview of the CRA Collections Process Canada Revenue Agency (CRA) has specific guidelines and periods regarding the collection of outstanding tax debts. Assessment and Notification: After filing a tax return, the CRA assesses the return and issues a Notice of
Covid Benefit Disputes When it comes to the Canada Emergency Response Benefit (CERB) or Canada Recovery Benefit (CRB) and similar Covid benefits, taxpayers disputing benefit denials have the option of two internal Canada Revenue Agency (CRA) reviews before pursuing an
First Nations Goods and Services Tax The FNGST provides a framework that allows First Nations governments to exercise tax jurisdiction on their lands. This tax operates similarly to the federal Goods and Services Tax (GST), with some critical differences aimed
SR&ED and Contemporaneous Documentation The SR&ED (Scientific Research and Experimental Development) policy in Canada advises that taxpayers claiming tax incentives for R&D activities maintain “contemporaneous documentation.” This refers to keeping detailed, accurate, and up-to-date records to support claims made for
GST/HST Input Tax Credits for First Nations Businesses In Canada, First Nations businesses often face unique challenges when it comes to managing taxes like the Goods and Services Tax (GST) and Harmonized Sales Tax (HST). These challenges stem from the
CRA Collections When taxpayers fall behind on their tax obligations, the Canada Revenue Agency (CRA) has broad powers to collect outstanding amounts. Whether you are an individual or a business, understanding the CRA’s collection process is critical to protecting your
New CRA Policy on Gross Negligence Penalties for SR&ED Claims The Canada Revenue Agency (CRA) has updated its enforcement approach for Gross Negligence Penalties under subsection 163(2) of the Income Tax Act, affecting Scientific Research and Experimental Development (SR&ED) claims. Effective January 28, 2025, these
Exceptions to the CRA Flipping Rules for the Sale of New Houses The Canada Revenue Agency (CRA) has introduced flipping rules that apply to the sale of real estate. These rules aim to ensure that profits from the sale of
Preparing for an Informal Procedure Tax Court Hearing Taking your tax dispute to the Tax Court of Canada is a significant step. Whether you’re filing under the informal or general procedure, proper preparation is critical to ensuring your case is presented
The New CRA Gig Economy Rules The Canada Revenue Agency (CRA) has introduced new rules that require digital gig economy platforms, such as Uber, Lyft, and DoorDash, to report income earned by their workers. CRA is trying to ensure tax
Disagreements with the Canada Revenue Agency (CRA) can arise from audits, reassessments, or penalties. Whether it’s a personal tax issue or a business-related matter, CRA disputes can be stressful and complex. Without expert guidance, you may face significant financial and