Tax Shelters

Understanding Canada's Personal Services Business (PSB) For Tax Purposes In Canada, the concept of a Personal Services Business (PSB) under subsection 125(1) of the Income Tax Act, R.S.C., 1985, c. 1 (5th Supp.) (“ITA”) is a critical tax classification that affects incorporated individuals who provide services...

Choptiany v. The King, 2022 TCC 112 The case of Choptiany v. The King, 2022 TCC 112 involved a tax scheme promoted by DeMara Consulting Inc. and Fiscal Arbitrators. It centered on convincing some taxpayers to unwittingly claim fictitious business losses and expenses to create large tax refunds. The Canada Revenue Agency...

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...

CRA Collections - Tax Shelters & Large Corporations CRA Collection Restrictions pursuant to Section 225.1 of the Income Tax Act Pursuant to section 225.1 (subsection 7) of the Income Tax Act, RSC 1985, c 1 (5th Supp), Canada Revenue Agency (“CRA”) can collect 50% of the disputed...