International Tax Issues
- Income Tax Residency
- Individuals
- Effect of Covid 19 travel restrictions on common law test and 183‐day deeming rule
- Corporations
- Effect of Covid 19 travel restrictions on determining "central management and control"
- Individuals
- Carrying on Business and Permanent Establishments
- Cross‐Border Employment
- Non‐Resident Employees
- Canadian‐Resident Employees
- Procedural Matters
- Regulatory Waiver Requests
- Dispositions of Taxable Canadian Property
Extension of Payment Deadlines
- Tax payment deadline extended to September 30
- Interest on existing tax debt waived for limited period
- Deadline for filing tax returns extended to September 30
- No extension for filings claims for Scientific Research and Experimental Development tax credits
- Amend Income Tax Act to provide flexibility for certain time limits
Charity Registration Applications
- Extension of time to respond to CRA's requests
- Can apply online for charitable status
- Audit activities are suspended
- T3010 filing deadline extended to December 31, 2020
Suspension of Limitation Periods
- Ontario limitation periods that were suspended on March 20, 2020 have resumed on September 14, 2020
- Federal limitation periods that were suspended on March 13, 2020 have resumed on September 13, 2020
Witnessing Formalities
- Wills and Powers of Attorney
- Remote execution permitted
- Temporary measure – current Order expires October 22, 2020
- Practicalities of remote execution
- Commissioning of Affidavits
- Amendment to s. 9 of Commissioners for Taking Affidavits Act ‐ permit remote administration of oath or declaration
- Regulation outlining procedure in force August 1, 2020
- Notarization of Documents
- Amendment to s. 3 of Notaries Act ‐ permit notaries to perform duties without being in person's physical presence by Regulation
- No Regulation permitting remote notarization made
Solicitor‐Client Communication
- Communicating with clients during a pandemic and compliance with LSO Rules of Professional Conduct
- Client identification and verification
- Assessing capacity virtually for Wills and Powers of Attorney
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.