Research Portal.
Search
Research Results
In 2017, about 60 percent of capital gains taxes were paid by those earning more than $250,000. In this manner, it is normal to expect
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
- Topics: Registered Charities
- Category: Commentaries
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 –
- ITA Sections: 125
- Category: Commentaries, Tax Legislation
Highlights of Bill Morneau’s 2018 fiscal update Overview Responding to U.S. Tax Cuts And Jobs Act of 2017 (TCJA): Enhance capital cost allowance (CCA) in
- ITA Sections: 20(1)(a)
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
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
- Category: Tax Legislation
Summary of Fall Economic Statement Overview Suggestions to the federal government to address U.S. tax reform Not going along with the federal government’s passive income
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
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
- ITA Sections: 9
The CRA has been relentless in scrutinizing real estate transactions: especially those conducted in the Greater Toronto Area and British Columbia. These regions have become
- Category: Tax Legislation
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
- Category: Tax Legislation
Budget 2018 At-Risk Rules for Tiered Partnerships The income (or loss) of a partnership for income tax purposes is allocated to its partners, who
- Topics: At-Risk Rules, Partnerships
- Category: Tax Legislation
Part IV Tax – Allocation of Losses ITA 129 New subsections 129(4.1) and (4.2) of the Act are introduced consequential to the introduction of
Passive Investment Income Budget 2018 Active business income earned by private corporations is taxed at corporate income tax rates that are generally lower than
- Category: Tax Legislation
Reassessment Period – Non-Resident Non-Arm’s Length Persons Budget 2018 After a taxpayer files an income tax return for a taxation year, the Canada Revenue
- Category: Tax Legislation
Foreign Affiliates Budget 2018 Budget 2018 proposes modifications to the foreign affiliate rules as a result of the Government’s ongoing monitoring of developments in
- Category: Tax Legislation
Cross-Border Surplus Stripping Using Partnerships and Trusts Budget 2018 The Income Tax Act contains a rule (section 212.1) that is intended to prevent a
- ITA Sections: 212.1, 212.1(1.1), 212.1(1.2), 212.1(1), 212.1(3), 212.1(4), 212.1(5), 212.1(6), 212.1(7)
Key Takeaway The decision in Laplante highlights a major pitfall that tax practitioners should be mindful of when advising clients on structures to multiply the
- ITA Sections: 104, 104(13), 104(24), 110.6, 110.6(2.1)
Under the current rules, a trust doesn’t have to file a T3 return if it did not earn income or make distributions in the year.
If a corporation opts to claim non-capital losses against Part IV tax using paragraphs 186(1)(c) or (d), proposed subsections 129(4.1) and (4.2) prescribe an ordering
As an auditor, did you ever wonder about your constraints in the following situations: Financial interest — having a financial interest in your clients Family — auditing