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Tax Disputes & Litigation
Contractor or Agent? A Crucial Difference When it Comes to Taxation
If there’s a lesson to be learned when it comes to contract law, it’s that language and details matter. Even a seemingly straightforward contract between two parties can lead to serious tax consequences if certain aspects of the business relationship are not properly addressed in the contract. In a recent case heard by the Tax Court of Canada, a taxpayer found himself in hot water after failing to collect HST during… Read More
Corporate Tax Planning
Deducting an Assistant’s Salary As a Salaried Employee
People who run their own businesses enjoy the ability to deduct a number of expenses from their income, such as instances where a spouse provides work for them in exchange for payment. Salaried employees, however, are not able to make similar claims without jumping through some significant hurdles. A recent decision from the Tax Court of Canada serves to highlight this important distinction. A Full-Time Sales Manager Working From Home The… Read More
Personal Tax Planning
Renouncing US Citizenship As a Tax-Avoidance Strategy: Is it Worth It?
In last week’s blog, we discussed the case of an American business owner facing stiff penalties from the IRS for failing to report income held in Canadian accounts. The obligation to file taxes in the United States on income earned in foreign jurisdictions should not be news to Americans or dual citizens since the implementation of the Foreign Account Tax Compliance Act (FACTA), but the reality of satisfying this obligation may involve more work… Read More
Tax Disputes & Litigation
American Business Owner Faces Penalties For Failing To Disclose Canadian Bank Accounts
We’ve had a number of blogs as of late discussing the United States’ Foreign Account Tax Compliance Act (FATCA). The legislation, introduced about ten years ago, empowers the IRS to pursue tax money from American citizens who have bank accounts in jurisdictions outside of the United States. Since the United States is virtually the only country in the world imposing taxation based on citizenship rather than residency, this means that Canadians who have… Read More
Personal Tax Planning
FATCA Fight Heads to the E.U.
Last week we blogged about the sharp increase in the number of financial records of Canadian taxpayers sent by the Canada Revenue Agency (CRA) to the Internal Revenue Service (IRS) under the often-controversial Foreign Account Tax Compliance Act (also known as FATCA). As uncovered by CBC News, the CRA sent 900,000 records to the IRS in September 2019: up from 700,000 the previous year. Overall, more than 2.5 million records have been provided to… Read More