The following article appeared in the most recent edition of The Hamilton Law Association Journal.
What is the difference between an estate and a trust? And why does it matter for tax purposes?
Audits
The federal government, stung perhaps by the charge that it goes after little fish (who can’t defend themselves) rather than the big fish (who can afford high-priced talent), has announced a significant expansion of the CRA’s audit capabilities for “suspected…
File Under “Annoying”
You can file the following under “Annoying”: a non-resident that voluntarily registers for GST will also be assigned a corporate income tax account automatically. The non-resident must then go to the trouble of having the account cancelled after proving to…
Life insurance changes
Grant Thornton’s Tax Release entitled “New rules for life insurance” does a good job of using English to explain some proposed changes to the Income Tax Act (Canada) and the Income Tax Regulations that will affect insurance policyholders. The Release…
Panama
From a CRA press release issued two days ago on the Panama papers: The Canada Revenue Agency (CRA) is committed to combating the abusive use of offshore jurisdictions and protecting the integrity of the Canadian tax system. The CRA continues…
Small business shares in RRSPs
From Daniel Gosselin, “Reversing Prohibited Status of Small Business Shares in RRSPs”, Tax for the Owner-Manager, 15:4 (October 2015): In a technical interpretation (TI 2015-0579671E5, May 28, 2015), the CRA confirms that the shares of a corporation that ceases to…
VD Data
The CRA personnel dealing with voluntary disclosures (VDs) were quite busy in fiscal 2015. Michael Friedman and Andrew Stirling, “Voluntary Disclosures Continue To Increase” Canadian Tax Highlights 24:3 (March 2016) discusses some key points found in the CRA’s report to…
US Issues in Canadian Tax Disputes
Roy Berg, in “Tax Dispute Resolution: Watch for US Issues” Canadian Tax Highlights 24:2 (February 2016), outlines some issues to consider when representing a US taxpayer who has a dispute with the CRA. He writes: The practitioner …
Jeopardy order
John Sorenson, in “Jeopardy Order Overturned” Canadian Tax Highlights 24:2 (February 2016), discusses Canada (National Revenue) v Grenon, 2015 FC 1050. In this case, the taxpayer applied to the court to overturn a jeopardy collection order made under section 225.2…
CRA Response
The CRA has responded to some Bad Press regarding the KPMG case, which I wrote about yesterday.