Pages
Categories
Archives
Category Archives: International
Antle and Garron
The Federal Court of Appeal has released its reasons for dismissing the appeal of the taxpayer in Antle. See Antle v. The Queen, 2010 FCA 280. The reasons are also now available online in St. Michael Trust Corp. v. The … Continue reading
Posted in Cases, Collections, Individuals, International
Leave a comment
T1135
A taxpayer is required to file a form T1135 in respect of foreign property, including foreign securities, even if the securities are held in a Canadian brokerage account. If you fail to file the form in these circumstances, and the … Continue reading
Posted in Cases, International, Miscellaneous
1 Comment
Double Taxation in US Health Care Reform
A recent Tax Court of Canada decision raises concerns of double taxation in proposed US health care reforms. The case is Niemeijer v. The Queen, 2009 TCC 624.
Posted in Cases, International
1 Comment
Failure to File Penalty
Subsection 162(2.1) of the Income Tax Act provides for a penalty for a non-resident corporation that fails to file a return and that it is liable to a penalty under subsections 162(1) or (2). The penalties provided by the latter … Continue reading
Posted in International
1 Comment
EBay released
eBay Canada Ltd. v. Canada (National Revenue), 2008 FCA 348 is now available on CanLII. The Court held that information on servers in the U.S. is not foreign-based information.
Posted in Cases, International
1 Comment
Michigan taxes
Michael Van Severen, who is a member of the cross-border tax services group at KPMG in Hamilton, was kind enough to forward to me a “Tax Tip-Off” (I thought it said “Tax Rip-Off” when I first received it). The tip … Continue reading
Posted in International
Leave a comment
Canada Approves
According to the Department of Finance website, “Canada Supports U.S. Technical Explanation of the Fifth Protocol to the Canada-United States Income Tax Convention“.
Posted in International
Leave a comment
Foreign tax credits
In Marchan v. The Queen, 2008 TCC 158, the taxpayer received stock options from the U.S. parent of the Canadian subsidiary for which he worked in Canada. He exercised the options and sold the underlying securities, but the brokers handling … Continue reading
Posted in Cases, International
Leave a comment
Withholding Tax Issues
In Sentinel Hill No. 29 Limited Partnership v. Canada (Attorney General), 2008 ONCA 132, the Ontario Court of Appeal held that the Superior Court is not the place to resolve disputes involving assessments under the Income Tax Act (Canada) (the … Continue reading
Posted in Cases, International
1 Comment
News releases
The CRA issued a couple of news releases yesterday. One of them warned about RSP “scams”, and the other announced that the CRA had issued a notice of suspension to ‘International Charity Association Network.’ The Department of Finance announced today … Continue reading