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New CRA Policy on Gross Negligence Penalties for SR&ED Claims

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

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Preparing For an Informal Procedure Tax Court Hearing

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

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The New CRA Gig Economy Rules

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

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Resolving CRA Disputes

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

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The CRA’s New Short-Term Rental Rules

In response to the growing popularity of short-term rentals and their impact on housing availability, the Canadian federal government has introduced new tax regulations effective January 1, 2024. These rules aim to ensure compliance with local laws and promote the

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The Tax Court of Canada and the Informal Procedure

When facing a tax dispute with the Canada Revenue Agency (CRA), the idea of taking the matter to the Tax Court of Canada might seem daunting. However, for smaller disputes, the Tax Court offers an informal procedure that is simpler,

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Accountant, Client and Legal Privilege

Coopers Park Real Estate Development Corporation v. The King, 2024 TCC 122   Accountant-Client privilege does not exist. However, under what circumstances could information or documents from an accountant or third-party be considered privileged and confidential in a legal proceeding?

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Section 85 Rollovers

Incorporating a business can be a powerful step toward growth, but it often comes with significant tax implications. Fortunately, the Income Tax Act offers Section 85 rollovers, a valuable mechanism allowing business owners to transfer assets into a corporation without

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Bare Trusts: A Simple Guide

In the world of tax and estate planning, various trust structures can help manage and protect assets. One such structure is the bare trust. Although bare trusts may seem simple, they offer unique advantages and considerations that can benefit individuals

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Offshore Audits: What You Need to Know

Offshore Audits: What You Need to Know In recent years, the Canada Revenue Agency (CRA) has ramped up its focus on offshore tax compliance, leading to a significant increase in offshore audits. These audits are designed to ensure that Canadians

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The Principal Residence Exemption

The Principal Residence Exemption The principal residence exemption is a significant tax benefit in Canada, shielding homeowners from capital gains tax when they sell their primary home. However, for a property to qualify for this exemption, it must meet certain

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The Power to Audit is the Power to Destroy

The authors of this article address the serious problem of lack of effective recourse for Canadian taxpayers where they are subject to the abusive exercise of audit and/or assessment powers by tax officials: The-Power-to-Audit-is-the-Power-to-Destroy-Judicial-Supervision-of-the-Exercise-of-Audit-Powers.pdf

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The CRA and Unreported Cryptocurrency

With the rise of cryptocurrency, the Canada Revenue Agency (CRA) has become increasingly vigilant in ensuring Canadians report all taxable income, including earnings from cryptocurrency. Although many crypto transactions occur online and may seem anonymous, the CRA has developed sophisticated

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Principal Residence Exemption Audits

Selling your home can be an exciting milestone, but it can also attract the attention of the Canada Revenue Agency (CRA). Homeowners often rely on the principal residence exemption to shelter capital gains from the sale of their principal residence

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CRA’s Expanded Audit Powers

The Government of Canada has recently proposed enhancing the Canada Revenue Agency’s (CRA) audit powers under the Income Tax Act. CRA already has vast powers to compel taxpayers to provide information and documentation. CRA can even force taxpayers to appear

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CRA’s Offshore Audits: What You Need to Know

CRA’s Offshore Audits: What You Need to Know In recent years, the Canada Revenue Agency (CRA) has significantly ramped up its efforts to combat offshore tax evasion. With the global economy becoming increasingly interconnected, CRA’s focus on offshore audits is

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Understanding Tax Residency in Canada

Determining tax residency is crucial for understanding your tax obligations in Canada. This blog will explore the factors the Canada Revenue Agency (CRA) considers when determining an individual’s tax residency status and how tax treaties, like the one between Canada

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Unreported Income and the Canada Revenue Agency

In Canada, the obligation to report income accurately to the Canada Revenue Agency (CRA) is not just a legal requirement but a cornerstone of our tax system. However, instances of unreported income can arise due to various reasons, sometimes inadvertently,

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