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Rotfleisch & Samulovitch P.C.
A butterfly reorganization is a method of separating a corporation – through its assets – into two or more separate corporations.
Rotfleisch & Samulovitch P.C.
As described in CRA publication T4041(E) Rev.20, an RCA is a plan or an arrangement under which an employer, former employer, and in some cases an employee makes contributions to a person or partnership, ...
Rotfleisch & Samulovitch P.C.
Canada has been criticized for failing to police and control the growth of underground currency exchange and banking networks in Toronto.
Rotfleisch & Samulovitch P.C.
When a taxpayer fails to file a tax return by the prescribed filing deadline, the Canada Revenue Agency may issue a tax assessment known as an "arbitrary" or "notional" tax assessment.
Rotfleisch & Samulovitch P.C.
In December 2020, the Canada Revenue Agency (CRA) issued over 650,000 letters to many self-employed Canadians regarding the repayment of the Canada Emergency Response Benefit (CERB).
Rotfleisch & Samulovitch P.C.
When a taxpayer fails to comply with his obligations under the Income Tax Act or other taxation statutes that the Canada Revenue Agency administers, the CRA will often apply penalties such as late-filing penalty, ...
Osler, Hoskin & Harcourt LLP
The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting [PDF] – also known as the Multilateral Instrument or MLI – entered into force ...
McKercher LLP
The federal government proposed new tax reporting rules for trusts in the 2018 budget, which have now come into effect for the 2021 and subsequent taxation years
Borden Ladner Gervais LLP
On February 18, 2021, the Supreme Court of Canada (SCC) declined to hear the appeal of the Canada Revenue Agency (CRA) from its loss before the Federal Court of Appeal (FCA) in Canada v. Cameco Corporation (2020 FCA 112) (Cameco).
Crowe MacKay LLP
On February 25, 2021, Alberta Finance Minister, Travis Toews, announced the 2021 Alberta Budget. Many of the Budget measures are meant to drive the province's investment in health care...
Watson Goepel LLP
This is the 2nd of a new 4-part business startup series created by Anand Athiviraham, Senior Associate in our Business Law Group
Lawyers Financial
For many Canadians, saving for important life goals can feel like an uphill struggle. But it doesn't have to be. There are tax-efficient structures in place to give Canadians of all ages...
Minden Gross LLP
A spousal RRSP is simply an RRSP where you make the contributions, but the plan is in your spouse's name – that is, it's owned by your spouse.
McCarthy Tétrault LLP
Yesterday, the Supreme Court of Canada dismissed the Minister of National Revenue's ("the Minister") application for leave to appeal in the matter of Canada v. Cameco Corporation, 2020 FCA 112.
Miller Thomson LLP
In the 2018 Federal Budget, the federal government proposed to increase reporting requirements for trusts and impose penalties for failing to comply.
Bennett Jones LLP
On February 18, 2021, the Supreme Court of Canada announced that it will not hear the transfer pricing tax appeal involving the Government of Canada and Cameco Corporation.
Rotfleisch & Samulovitch P.C.
There are two types of residence for taxpayers; their immigration residence and their tax residence. A taxpayer can be resident of one country for immigration purposes and resident of an entirely different country for tax purposes.
Rotfleisch & Samulovitch P.C.
Under the Income Tax Act, Canadian residents must pay tax on their worldview income, while non-Canadian residents must pay tax on their Canadian-sourced income.
Rotfleisch & Samulovitch P.C.
Allstaff Inc. (the "Taxpayer") is a temporary employment agency that employed its own workers and contracted them out to its clients.
Gowling WLG
On February 9, Chief Justice ("CJ") Rossiter of the Tax Court of Canada ("TCC") provided the third TCC reopening update. Here are our top ten highlights.
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