Tax Practitioner Resources
Legislation| Canada & U.S.
Delaware
OECD Resources
OECD Resources | BEPS Action Plans, Model Convention, Transfer Pricing Guidelines
Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS
United Nations Resources
United Nations Resources Treaty and Transfer Pricing Documentations
Canadian Case Law
Important SCC Cases
Tax Avoidance
Residency of Trusts
Treaty Interpretation
Residency in Tax Treaties
Employment Income
Employee vs. independent Contractor
Fringe Benefits
Business Income
Reasonable Expectation of Profit
Tenant Inducement Payments
Deduction of Hobby Farming Losses
Business Income (Cont'd)
Receivable and Holdbacks
- MNR v. J. Colford Contracting Co. [1960] CTC 178 || 1960
- Minister of National Revenue v. Benaby Realties Limited, [1968] SCR 12 || 1967
Royalties
Blended Interest and Principal Payments | Converting Interest Income into Capital Gains
Entertainment Expenses
Personal vs. Business Expenses
Deduction of fines, penalties or statutory levies from income
Absolute vs. Contingent Liability
Foreign Exchange Loss
Inventory vs. Capital Property
Legal Test for Interest Deductibility
Interest Deductibility - Direct Link Test
Interest Deductibility - Filling in the Hole
Interest Deductibility - Original Property Replaced: Tracing Principle
Business Income (Cont'd)
Income vs. Capital
Peripheral land
Capital Gains
Including Assigned Liabilities as Part of Proceeds of Disposition
Other
Rectification to Avoid Adverse Tax Consequences
Attribution on Discretionary Dividends
Qualifying vs. Unqualifying Amalgamations
Transfer Pricing
Statutory Interpretation
Transactions Without Bona Fide Business Purpose
Sham
Meaning of Control
Existance of a Valid Partnership
CRA Resources
A. Folio Views
Series 1 Individuals
Folio 1 Health and Medical
Folio 2 Students
Folio 3 Family Unit Issues
Folio 4 Personal Credits
Folio 5 Transfers of Income, Property or Rights
Folio 6 Deceased Individual/ Death of a Taxpayer
- Forthcoming
Series 2 Employers and employees
Folio 1 Specific Plans Offered by Employers to Employees
Folio 2 Employment Expenses
Folio 3 Employment Benefits
Folio 4 Information Specific to Particular Fields of Employment
- Forthcoming
Series 2 Employers and employees
Folio 1 Specific Plans Offered by Employers to Employees
Folio 2 Employment Expenses
Folio 3 Employment Benefits
Folio 4 Information Specific to Particular Fields of Employment
- Forthcoming
Series 3 Property, investments and savings plans
Folio 1 Shares, Shareholders & Securities Transactions
- Forthcoming
Folio 2 Dividends
Folio 3 Capital Transactions
- Forthcoming
S3-F4-C1, General Discussion of Capital Cost Allowance
Folio 5 Eligible Capital Property
- Forthcoming
Folio 6 Interest
Folio 7 Real Estate or Rental Properties
- Forthcoming
Folio 8 Resource Properties
Folio 9 Miscellaneous Payments/Receipts
Folio 10 Registered Plans for Individuals
Folio 11 Transfers between Registered Plans
- Forthcoming
Series 4 Businesses
Folio 1 General Business Concepts
- Forthcoming
Folio 2 Deducting Business Expenses
Folio 3 General Principles of Business Income Calculation
Folio 4 Corporations – Status & Structures
- Forthcoming
Folio 5 Tax Deferred Rollovers
Folio 6 Provisions Applicable to Specific Corporations
- Forthcoming
Folio 7 - Wind-ups, Dissolutions and Amalgamations
Folio 8 Losses
- S4-F8-C1, Business Investment Losses
Folio 9 Bad Debts & Debt Forgiveness
- Forthcoming
Folio 10 Inventory
- Forthcoming
Folio 11 Farmers
Folio 12 Contractors & Construction
- Forthcoming
Folio 13 Income from Professional Practices
- Forthcoming
Folio 14 Income from Artistic Endeavours
- Forthcoming
Folio 15 Manufacturing and Research & Development
Folio 16 Partnerships
Series 5 International and residency
Folio 1 Residency
Folio 2 Foreign Tax Credits and Deductions
Folio 3 Cross-border Issues
- Forthcoming
Folio 4 Foreign Currency
Series 6 Trusts
Folio 1 Trusts and Residency Issues
- S6-F1-C1, Residence of a Trust or Estate
Folio 2 Beneficiaries
Folio 3 Taxation of an Intervivos Trust and Attribution
- Forthcoming
Folio 4 Testamentary Trusts
- Forthcoming
Series 7 Charities and non-profit organizations
Folio 1 Charitable Gifts and Deductions
Folio 2 Non-profit Organizations
- Forthcoming