The Department of Finance Canada’s Budget 2015 proposes to put into operation a new streamline reporting system for foreign assets. Presently, Canadian resident individuals, partnerships, corporations, and trusts that own a total value of more than $100,000 of specified foreign property must disclose detailed information regarding each property by filing Form T1135, Foreign Income Verification […]

If a Canadian taxpayer owns certain foreign property, the collective cost of which exceeds $100,000 CDN, the taxpayer must file a Form T1135 (Foreign Income Verification Statement). The Canada Revenue Agency (“CRA”) recently provided its views on whether digital currency is considered “specified foreign property” under the reporting rules in section 233.3 of the Income […]

July 22, 2015 – Global News reports on the issues surrounding taxes and companies such as Uber and Etsy in their “Booming shared economy leaves governments of all levels scrambling to keep up on taxes.” See Dale Barrett’s comments regarding the issue and planning ahead here. CLICK HERE TO BOOK A CONSULTATION WITH A TAX LAWYER

In 2010, Donna Marie Stancer and Deanna Lynn Lavalley started a tax consultation company by the name of DeMara Consulting Inc. It wasn’t until March of 2012 that the Canada Revenue Agency (the “CRA”) raided the DeMara Consulting Inc. office in downtown Vernon looking for evidence of tax evasion. Stancer and Lavalley had been marketing […]

Today, many Canadians own real property in the U.S. as vacation or rental property. There are various ways to hold such property, and the choice of how to hold your foreign real estate depends on the goal(s) you wish to achieve. Some of these goals may include avoiding ancillary probate in the U.S., deferring, reducing […]

Generally, the test applied to determine the residency of a trust is where its “central management and control” is located. The Newfoundland Supreme Court rendered a decision which recognizes the reality of the “trust” relationship. In Discovery Trust v. Minister of National Revenue, the trust filed its 2008 return indicating it was a resident of […]

July 20, 2015 – The Ottawa Business Journal published a blog post written by Barrett Tax Law’s Ottawa Managing Lawyer, Michael Citrome. “Here in Ottawa, many people think of the government as an employer, rather than as an obstacle to doing business. Even still, for many entrepreneurs, the government may seem like a monolithic thing […]

There is a common misconception that all communications with a lawyer are privileged. A recent Federal Court case, Canada (National Revenue) v. Revcon Oilfield Constructors Incorporated, 2015 FC 524, is a reminder that not all communications with a lawyer are protected by solicitor-client privilege. Specifically, the court pointed out that tax planning communications are not […]

Are you a shareholder of a non-arm’s length company and also employed for the same corporation? If so, you should think carefully before making an agreement where you are paid in dividends instead of being paid a salary or other form of compensation. If dividends are distributed when the corporation has a tax debt, the […]

With the passing of this new section, the Minister is now allowed to collect 50% of the amount assessed in respect of a tax shelter even if the related assessment is in dispute. Meaning even if you object, or appeal to Tax Court, the Minister can still come after you for half the amount owing. […]