Recent Articles

Treaty Shopping Explained - Velcro Canada Inc. v. The Queen

March 12, 2012 20:29

The Canada Revenue Agency (“CRA”) recently lost in Tax Court against a taxpayer that had structured their operations to minimize Canadian tax. The case, Velcro Canada Inc. v. The Queen, (“Velcro Canada”) is the first case since the FCA decision of Prevost Car Inc. v....

The Upcoming 2012 Canadian Federal Budget

February 22, 2012 16:52

As mentioned in an earlier post, the Federal Budget is usually the place where most tax proposals arise. Accordingly, tax practitioners are keenly interested in the detailed Budget proposals that get released. However, as we have mentioned in earlier posts, there are also many income tax amendments...

New Regulations Clarify Non-US Banks Will Find and Report US Customer to the IRS

February 13, 2012 22:53

Roy A. Berg JD. LL.M. (US Tax) & Nicholas J. Dancey JD, LL.M. (US Tax)   On February 08, 2012 the IRS issued IR 2012-15, which contains proposed regulations that clarify the manner in which non-US financial institutions will find and report US persons to the IRS, which is required by the...

Some Short Answers / Rebuttals to Common Tax Myths

February 13, 2012 22:40

The study and practice of tax is tough. I have said it before and I'll say it again, I believe that tax is one of the most difficult areas of practice in existence. In my many years of being a tax specialist, there have been no shortages of "tax myths" that I have run across and dealt...

A Mild RRSP Season - Except for the Advantage Rules

February 03, 2012 21:31

RRSPs are an extremely popular investment vehicle for Canadians. With the mild weather, it may be easy to forget it is February and the RRSP deadline is February 29th. (The deadline is usually March 1, but with 2012 being a leap year it will be the last day of February.) This RRSP...

Filing On The Basis Of Proposed Tax Legislation

February 01, 2012 21:30

This is not a new topic. However, it is one that we deal with time and time again....especially in recent years. Tax policy and the implementation of tax legislation in Canada is under the purview of The Department of Finance. Much of Canada's new tax legislation arises from the annual Federal...

The Top 5 Tax Mistakes Made By Private Client Canadian Practitioners

January 13, 2012 22:19

Firstly, this is my list not yours. It is very subjective and is a reflection of my many years of experience of being a tax specialist and building a “tax only” advisory practice. Most of the practitioners that are clients and friends of our firm know their tax...

Copthorne Holdings: A Nasty Holiday Gift for Taxpayers from the Supreme Court of Canada

December 20, 2011 20:46

Posted by Roberto Domagas CA and Robert Worthington LL.B. Copthorne Holdings Ltd. v. Canada, 2011 SCC 63 (CanLII) is a recent decision from the Supreme Court of Canada regarding the general anti-avoidance rule (“GAAR”)[1] and provides the much-anticipated interpretation and...

IRS Says No New Relief Planned For Canadians

December 16, 2011 20:56

On December 15th and 16th I attended the International Taxation conference sponsored by the IRS and held in Washington DC.  There were more than 700 people in attendance and the lunchtime speaker on the first day was Douglas Shulman, the Commissioner of the IRS. At the end of his prepared...