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Recent Publications - Transactions

Recent Publications

July 26, 2023 by Mike Hayward, Dean Morris

BT Canada offers recommendations on transfer pricing reform

At Baker Tilly Canada, we are committed to helping ensure fairness and integrity in the Canadian tax system.

As part of this commitment, we are grateful for the opportunity to provide our input on the Department of Finance consultation paper regarding reform and modernization of Canada’s transfer pricing rules.

May 25, 2023 by Dean Morris

Transfer pricing and small‑ to medium‑sized enterprises

Much like large global companies, small‑ to medium‑sized enterprise multinational enterprises (MNEs) may be subject to complex transfer pricing requirements. As governments increasingly seek to protect their tax base, our new Tax Alert focuses on the transfer pricing challenges and considerations facing small‑ to medium‑sized enterprise MNEs.

March 14, 2023 by John F. Oakey

FBAR penalty – A welcomed decision by the Supreme Court

On Feb. 28, 2023, the U.S. Supreme Court ruled in the case of Bittner v. United States1 that the non‑willful penalty for failure to file the Foreign Bank and Financial Accounts (FBAR) report was on a per report basis, not per account basis.

December 13, 2022 by Shelley Smith

Borders without (tax) boundaries – Navigating U.S. returns in a cross‑border setting

United States citizens and Green Card holders are both considered U.S. persons, regardless of where they live. U.S. persons living outside the U.S. (such as in Canada) must continue to file U.S. tax returns annually, even if they have no income from the United States. For such individuals, there are mechanisms to avoid or reduce U.S. tax exposure and, in many cases, end up owing no U.S. tax at all. Still, failure to file returns, related forms and certain foreign information reporting can result in significant penalties.

October 25, 2022

To file or not to file – Considerations for late‑filed GST/HST section 156 elections

GST/HST is generally applicable when property and/or services destined exclusively for commercial purposes are supplied by a closely related party who is registered for that tax. To simplify tax accounting and improve cashflow, certain closely related Canadian corporations and partnerships can elect under subsection 156(2) of the Excise Tax Act, via Form RC4616, to treat certain supplies by a closely related person as if they were made without consideration.

July 26, 2022 by Riccardo Zerbino

Voluntary Disclosures Program not to be taken lightly

Our new Tax Alert highlights how past amendments by the Canada Revenue Agency (CRA) to the Voluntary Disclosures Program (VDP), along with recent court decisions, demonstrate the VDP should be used with extra caution. For those seeking immunity from interest and penalties, it is clearer than ever the VDP has become more restrictive, signaling the CRA’s heightened desire to combat tax evasion.

June 30, 2022 by Sarah Perrin, Carl Scholz

Amendments to the General Anti-Avoidance Rule – subtle changes not to be ignored

Our new Tax Alert explains how subtle yet significant proposed amendments to the General Anti-Avoidance Rule (GAAR) can provide taxpayers and the Canada Revenue Agency (CRA) greater certainty and clarity. These proposed changes may also help reduce impractical and inefficient use of CRA resources. It all adds up to a proposal that should not be ignored.

June 3, 2022

Time is running out to fill your prescription — for a prescribed rate loan, that is

Our new Tax Alert explains how a prescribed rate loan can help lower your tax bill through income-splitting with a lower-income family member. However, the current prescribed rate will soon increase. That means now’s the time to lock in a lower rate to take full advantage of this tax savings strategy.

November 23, 2021

Sourcing and closing better deals with PitchBook

In its role as a financial advisor, Baker Tilly Canada Corporate Finance (BTCCF) helps small- to mid-size companies execute sell-side, buy-side and valuation engagements. 

November 19, 2021 by Shaun Andresen

A streamlined procedure does not clear a GILTI conscience

In December 2017, President Trump signed the Tax Cuts and Jobs Act (TCJA) into law. The TCJA made significant amendments to the Internal Revenue Code (IRC). Among them was the introduction of a transition tax under IRC section 965—a tax on accumulated earnings of certain foreign corporations in the hands of U.S. shareholders. This new tax marked a transition to taxing the active income of foreign corporations.

June 7, 2021 by Eric Gagnon

A hot housing market and a change in use equals tax with no cash. But there is a solution.

Most Canadians know that selling their home normally will not result in income tax thanks to the principal residence exemption (PRE). Unfortunately, people tend to extend this "knowledge" into a feeling that they need never worry about tax when dealing with their principal residence.

August 22, 2019 by Jamie Welsh, Sheldon Taylor

Fear and loathing in lost funds

 As the blockchain space continues to evolve towards mainstream adoption, the complexity of issues associated with blockchain-based technologies continues to grow. Given the vast number of uses for blockchain technology and the likelihood that it will continue integrating into the world around us, it is important to understand the nature of decentralized technology and its basis of operations.

September 21, 2018 by

Farm corporations: you don’t need to “go all in”

Accountants regularly advise of the tax and accounting benefits available to corporations. But there remain some producers who are reluctant to take the next step and incorporate their farm operations. With some recent harvest reports of higher than average yields, it is time once again to look at the pros and cons of incorporating.

July 30, 2018 by Bob Boser

Avoiding and Getting Off of The TOSI Highway

On July 18, 2017 the Federal Finance Minister announced proposals to change the tax rules related to income splitting using private corporations. The original proposals were subsequently withdrawn in October, re-released in December and after further changes the proposed legislation was included in Bill C-74 in March 2018. Bill C-74 received Royal Assent on June 21, 2018 and the new tax on split income (TOSI) rules are now in effect as of the beginning of 2018.

July 11, 2018 by Chris Russell

Business valuations 101 – Redundant assets: to be, or not to be?

There are numerous components that go into valuing the assets of an active business. In simplified terms, those components can be characterized as the value of normalized discretionary cash flow plus redundant assets. In this article, we will be discussing two of the more common redundant assets that business owners frequently do not realize exist within their organization.