Articles

Canadian Government Lifts Restrictions on Political Activities by Registered Charities

On October 31, 2018, the Government introduced proposed legislation as part of the Budget Implementation Act, 2018, No. 2 to change the rules for charities so that they have the full ability to pursue their charitable purposes by engaging in non-partisan political activities and the development of public policy. Specifically, the legislation proposes to: Remove […]

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Quebec to Follow Federal Government on Limiting the Small Business Deduction for CCPCs Earning Passive Income

Quebec’s government announced that it will amend its tax legislation to parallel the federal government’s measure – announced as part of the 2018 budget – to grind down the small business deduction limit for CCPCs having between $50,000 and $150,000 in investment income for taxation years that begin after 2018. Quebec’s government announced the following:

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Looking Forward to the 2018 Federal Fall Economic Update

Looking Forward to the 2018 Federal Fall Economic Update There have been mumblings that Bill Morneau’s 2018 fall economic update will have measures to incentivize capital investments in Canada. One of those measures is allowing businesses to write off their capital assets quicker (even immediately expensing them). Since the motive behind this anticipated change is

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Are You A Non-Resident Entity Carrying on Business in Canada?

Are You A Non-Resident Entity Carrying on Business in Canada? Non-resident Corporations A non-resident corporation is taxable on its income generated from a business carried on in Canada and from the disposition of taxable Canadian property.  This article focuses on business income. Business income Where a non-resident corporation is a resident in a country with

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The Federal Court of Appeal Applies GAAR in a Partnership Loss Transfer Strategy: Canada v. 594710 British Columbia Ltd., 2018 FCA 166

Overturning the Tax Court of Canada’s (Tax Court) decision, the Federal Court of Appeal (FCA) ruled in 594710 British Columbia Ltd that GAAR is applicable in a loss utilization strategy where a new partner (Nuinsco) with a significant unused loss balance entered a partnership to facilitate an allocation of virtually all the partnership’s income, availing the former

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Tax Court Rules Rental Losses Not a Source of Income in Hustak v. The Queen, 2018 TCC 199

Key Takeaway The Tax Court finds no source of income in a case involving a taxpayer claiming “rental losses” over a few years. Although the properties were clearly investment properties, the taxpayer did not act in a business-like manner to show that rental is a source of income. Tax practitioners must be wary of rental

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Notice of Ways and Means Motion October 2018: T1134 Reporting Requirements More Lenient than Proposed in 2018 Budget

T1134 Reporting Requirements   Budget 2018 Proposal The Income Tax Act contains specific information reporting requirements in respect of foreign affiliates. In general terms, taxpayers (and certain partnerships) are required to file an information return each year in respect of each of their foreign affiliates in the year T1134). These returns contain, among other things, information about

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