Taxation of BeneficiariesUnder subsection 104(13) of the Canadian Income Tax Act (“ITA”), the income of a trust or estate that is paid or payable to a...
Trusts and AttributionThe attribution rules for trusts, transferors, and so on are given in Subsections 74.1(1) and 74.2(2) of the Canadian Income Tax Act (“ITA”). These...
Taxation of TrustsThe taxation of trusts and their beneficiaries are dealt with under Sections 104 to 108, inclusive, of the ITA. The fundamental principle with respect...
What is a Trust?The word “trust” has not been defined in the Income Tax Act (ITA), nor is there any definitive guideline to establish whether or not a...
Registered Retirement Savings Plans (RRSPs)Like non-depreciable capital property and depreciable capital property, a spousal rollover is available for RRSPs. Money directly received by the spouse (as...
This article is attempting to illustrate the type of reasoning necessary in order to decide if an asset purchase or share purchase of an incorporated business...
The GAAR: Overriding, Overarching or Just Over?In most legal structures, rules and regulations tend to expressly or implicitly instruct or guide a person or any other...
The most basic form of business organization, used in a wide variety of circumstances, is called a sole proprietorship. Such organizations are relatively inexpensive to set...
Under section 116 of the Canadian Income Tax Act, non-resident vendors disposing of certain taxable Canadian property (partially listed below) are to notify the Canada Revenue...
Proactive and preemptive tax strategizing is important when filing an income tax return. The income and excise taxation of Canadian real estate would primarily depend on...