Tax Planning

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, c. 1 (5th Supp.)) establishes the reporting and...

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 in the decision in Devon...

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 at recognizing and accommodating the unique legal and cultural...

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 complexities surrounding tax exemptions and entitlements under the...

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 compliance within the rapidly growing gig...

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 availability of long-term housing options. DENIAL OF EXPENSE DEDUCTIONS FOR...

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 triggering immediate tax consequences.WHAT IS A SECTION 85 ROLLOVER?Section 85...

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 and businesses alike. WHAT IS A BARE TRUST? A bare trust is a type of trust where the...

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 and the United States, come into play.Tax Residency: The BasicsIn general,...

Moving to a new country like Canada can be an exciting adventure for expatriates, but it also comes with certain tax implications that must be carefully navigated. For expatriates residing in Toronto, the Greater Toronto Area, and other locations, understanding Canadian tax laws is crucial to ensure compliance and minimize tax liabilities. In...