The Federal Court Decides That CRA Enforcement Action on a Related Person Doesn’t by Itself Disqualify a Taxpayer From the Voluntary Disclosures Program. But is 40538993 Canada Inc. Still Relevant? – A Canadian Tax Lawyer’s Analysis
Introduction – The Voluntary Disclosures Program, CRA Discretion, and Judicial Review 40538993 Canada Inc. v the Minister of National Revenue (2019 FC 51) demonstrates why […]
Read moreCommon Reporting Standard is Now Fully in Effect – If You Have Been Hiding Funds or Assets Offshore, Now is the Time to Disclose
Introduction – Offshore funds and Canada Revenue Agency’ reach Gone are the days when offshore bank accounts were outside the Canada Revenue Agency (CRA)’s reach. […]
Read moreProposed Changes to the Voluntary Disclosures Program (VDP) – Conditions of a Valid Disclosure
Proposed Changes to the Voluntary Disclosures Program (VDP) – Conditions of a Valid Disclosure – A Canadian Tax Lawyer Analysis Proposed Changes to the Voluntary […]
Read moreProviding VDP Relief - Voluntary Disclosures Program Proposed Changes
Providing VDP Relief - Voluntary Disclosures Program Proposed Changes - Toronto Tax Lawyer Analysis Introduction – Voluntary Disclosures Program Proposed Changes The Voluntary Disclosures Program (VDP or […]
Read moreProposed Changes to the Voluntary Disclosures Program (Vdp) - How to Submit a Voluntary Disclosure
Proposed Changes to the Voluntary Disclosures Program (VDP) – How to Submit a Voluntary Disclosure – A Canadian Tax Lawyer Analysis Proposed Changes to the […]
Read moreProposed Changes to the Voluntary Disclosures Program – A Canadian Tax Lawyer Analysis
Proposed Changes to the Voluntary Disclosures Program (VDP) – A Canadian Tax Lawyer Analysis Voluntary Disclosures Program (VDP) – Current Rules The Voluntary Disclosures Program […]
Read moreCanadian Tax Treatment of Individual Saving Accounts in the United Kingdom
Canadian Tax Treatment of Individual Saving Accounts in the United Kingdom – A Toronto Tax Lawyer Analysis What is an Individual Savings Account? The term […]
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Income Tax Act’s Deemed Dividend Rules – Canadian Tax Lawyer Analysis
The Deemed Dividend Rules under Section 84 of the Income Tax Act– Canadian Tax Lawyer Analysis Introduction – The Definition of a Dividend and a […]
Read moreOECD List of Uncooperative Tax Havens – International Information Sharing
OECD List of Uncooperative Tax Havens – International Information Sharing – A Canadian Tax Lawyer Commentary The Classification of Uncooperative Countries The OECD has periodically […]
Read moreVoluntary Disclosure for Late Tax Return Filing for Non-Charitable Not-for-Profit Organizations
Voluntary Disclosure for Late Tax Return Filing for Non-Charitable Not-For-Profit Organizations – A Toronto Tax Lawyer Analysis Non-Charitable Not-For-Profit Organizations Tax Return Filing Requirements Non-charitable […]
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"These articles provide information of a general nature only. It is only current at the posting date. It is not updated and it may no longer be current. It does not provide legal advice nor can it or should it be relied upon. All tax situations are specific to their facts and will differ from the situations in the articles. If you have specific legal questions you should consult a lawyer."