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Impôts indirects
GST/HST Documentary Requirements and Common Audit Issues
<p>We continue to see Canada Revenue Agency (CRA) auditors aggressively challenge GST/HST registrants with the documentary requirements under subsection 169(4) of the <em>Excise Tax Act</em> (ETA).</p>
Cathie Brogan 23 oct. 2014
Services de conseils fiscaux
Streamlined and OVDP Update
<p>U.S. persons looking to catch up on required U.S. income tax filings may now be able to take advantage of an updated set of &ldquo;taxpayer friendly&rdquo; rules introduced in June 2014: the Streamlined Filing Compliance Procedures (Streamlined Program), and the Offshore Voluntary Disclosure Program (OVDP). These programs are integral parts of the ongoing Internal Revenue Service initiative to encourage U.S. taxpayers, particularly those located outside the U.S., to become compliant.</p>
9 sept. 2014
Services de conseils fiscaux
The Testamentary Trust Amendments: No Fairness for Most Disabled Canadians
<p>Despite the objections of The Canadian Bar Association (CBA), the Chartered Professional Accountants of Canada (CPAC) and the Society of Trust and Estate Practitioners (STEP), the 2014 Federal Budget introduced legislation to eliminate the graduated rate of taxation for testamentary trusts.</p>
5 sept. 2014
Services de conseils fiscaux
Income Tax Considerations in Structuring Real Estate Transactions with Life Interest
<p>A life interest in real estate provides an exclusive right to use a property during the lifetime of the holder of the interest. Often, an individual will incorporate a life interest on a transfer of a property by way of gift to a relative in order to ensure that the individual has use of the property during their lifetime, to know for certain who will own the property when they die, and to avoid probate fees upon death.</p>
11 août 2014
Impôts indirects
Application of GST/HST to Condominium Fees
<p>Provinces have legislation that allows for the creation of not-for-profit entities to collect fees from owners of certain real property to pay expenses for the upkeep and maintenance of the property. These entities are often known as condominium corporations. The issue then arises as to whether or not GST/HST applies to the fees being charged.</p>
7 août 2014
Services de conseils fiscaux
Safe Income Strips
<p>Safe income accumulates to particular shareholders on a per-share basis, with consideration given to the holding period of the share. This can result in differing amounts of safe income for different shareholders, particularly where reorganizations have occurred in the past or where shares have changed hands. As a result, an understanding of the share ownership history is required.</p>
Darlene Shaw Greg Leslie 23 juill. 2014
Services de conseils fiscaux
The Registered Disability Savings Plan and the Accident Victim
<p>The Registered Disability Savings Plan (RDSP) is a government initiative intended to assist eligible Canadians with disabilities and their families in saving for their long-term financial security. It is effective for 2008 and later taxation years. Individuals who are disabled or have become disabled as a result of an accident may be in a position to take advantage of the RDSP.</p>
11 juill. 2014
Services de conseils fiscaux
Coming to Canada Across the Canada-U.S. Border? Big Brother is Watching!
<p>On June 30, 2014, officials with the Canada Border Services Agency and the U.S. Department of Homeland Security commenced a cross-border information exchange initiative, whereby certain information on individuals crossing the border will now be shared between the countries&rsquo; border officials. Included in this shared information will be biographical data and the number of days spent in each country, which may be used by each country&rsquo;s governmental departments to ensure compliance with, among other things, income tax, immigration and health care regulations.</p>
11 juill. 2014
Services de conseils fiscaux
U.S. Federal tax rules applicable to loans from a Canadian parent to a U.S. subsidiary
<p><strong>Financing a U.S. subsidiary</strong></p> <p>When a Canadian company creates a U.S.-based subsidiary, one of the first issues to be addressed is how to fund those operations. Generally, funds may be advanced in the form of equity, debt or a combination of both.</p>
29 mai 2014
Services de conseils fiscaux
U.S. citizens and Canadian trusts
<p>Trusts are important tools in Canadian tax and estate planning.&nbsp;Discretionary family trusts, in particular, have become common and are continually evolving. Some of the most powerful benefits of these tools include:</p> <ul> <li><strong>Flexibility</strong> &ndash; the ability to maintain control of assets while directing income and value as the trustees see fit.</li> <li><strong>Income splitting</strong> &ndash; directing income of the trust to lower-income beneficiaries (usually family members) to minimize the overall family tax burden.</li> <li><strong>Capital splitting</strong> &ndash; allocating capital gains to beneficiaries, enabling the use of multiple capital gains exemptions.</li> </ul>
Todd King 29 mai 2014
Services de conseils fiscaux
Mitigating U.S. Tax exposure through the Closer Connection Statement
<p>Canadian persons that spend significant time in the United States can become subject to U.S. taxation and reporting requirements unexpectedly, even if they are not earning income from U.S. sources.&nbsp; Starting June 30th, 2014 a new initiative will begin that is designed to track a Canadian person&rsquo;s movement across the Canada/U.S. border.&nbsp; Prior to this new initiative, many Canadian persons felt, perhaps justifiably, that U.S. authorities had no way of actually knowing how many days they were present within their border.</p>
29 mai 2014
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