Tax Appeals with the Canada Revenue Agency – A Brief Summary

Appealing the Notice of Reassessment When the Canada Revenue Agency believes that a tax return of a given year was filed incorrectly or with errors, they will usually issue a Notice of Reassessment to the taxpayer highlighting the changes to their returns for that year or years. The taxpayer’s first step in disputing the CRA’s […]

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The Section 85 Rollover

Section 85 Rollover Overview Section 85 of the Income Tax Act (ITA) is an important tax planning tool that allows corporations to defer taxation in certain transactions that are often seen in incorporations and corporate reorganizations. Simply put, a section 85 rollover allows a taxpayer to transfer eligible property on a tax-deferred basis to a […]

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The Butterfly Transaction

Why do we call it a Butterfly? A butterfly transaction is a way to divide up assets in a corporation, or a set of corporations, in a tax-efficient manner under the Income Tax Act. These kinds of transactions typically involve rollovers under section 85 of the Income Tax Act which allows a taxpayer to transfer […]

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Cryptocurrency

The Basics In 2009, the first decentralized cryptocurrency, bitcoin, was created as open-source software. A little over a decade later, the cryptocurrency economy has exploded onto the world stage, with a value of more than $3 trillion at the time of writing this article. Cryptocurrencies generally do not exist within the purview of a central bank, […]

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Principal Residence

What is a principal residence? With the average price of Canadian homes rising at rates higher than ever, it’s not unusual for homeowners to want to try to reduce taxes owing on any potential taxes that may result from the sale of a property. Luckily for many homeowners, the Canadian Income Tax Act (“ITA”) lets […]

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Net Worth Audit

What is a Net Worth Audit? The Net Worth Audit is a method used by the Canada Revenue Agency (“CRA”) to calculate a taxpayer’s income based on the increases to their wealth in a given audit period. Effectively, the CRA compares a taxpayer’s assets and liabilities in one year against the assets and liabilities of […]

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The Voluntary Disclosure Program

  The Scenario Earlier this year, I met with a client who had immigrated to Canada some ten or so years ago. As is often the case for many immigrants, the process of bringing over one’s life savings and other assets to a new country can be a long and arduous process that takes a […]

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