As personal tax season has arrived, we thought it might be helpful to discuss a recently published technical interpretation from CRA (2022-0923881I7) covering a subsection 45(3) change in use election. Of the four questions asked of CRA, three could be very relevant to your practice.
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These are a summary of the requirements to have paragraph 84.1(2)(e) apply to a sale, which is the provision that allows these transactions to occur and not otherwise offend the anti-avoidance provisions of section 84.1.
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Application of Part IV Tax to Amalgamations of Companies Owned by Trusts with Corporate Beneficiaries
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Application de l’impôt de la partie IV aux fusions de sociétés détenues par des fiducies avec des sociétés bénéficiaires
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FAPI and TOSI Overlap: 107 Percent Tax Is Not Fair
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Affiliation Election for CEWS: Private Corporation Applications
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The New Passive Income SBD Grind Rules: When Do We Start? Part 2
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The New Passive Income SBD Grind Rules: When Do We Start?
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The 2018 federal budget added paragraph (b) to subsection 125(5.1) to penalize certain CCPCs that earn excessive invest- ment income.
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Canada Revenue Agency recently addressed some specific situations regarding its administration of tax on split income (TOSI).
In October 2019, two CRA comments related to TOSI were issued at the APFF Roundtable in Montreal and published as Tax Interpretations.
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Many small businesses hire ‘contractors’ to assist their companies to pursue various endeavours. Determining whether he or she should be properly classified for tax purposes as an employee or as a self-employed independent contractor may require further analysis from your accounting professional. This may require having to file a Voluntary Disclosures Program application with CRA.
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A double penalty can be assessed against taxpayers who file a Form T1135 Foreign Income Verification Statement that is both late and contains incomplete information, but only under certain circumstances, says Canada Revenue Agency.
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