Canadian Tax Tips

I. Introduction: Since 1988, Canadian tax pundits commonly retreat from opining on whether the Minister of National Revenue will successfully reassess any given taxpayer benefits arising from any novel series of tax avoidance transactions, with the ever-elusive, potentially omnipotent, and philosophically teleological, general anti-avoidance rule, [hereinafter, “GAAR”]. GAAR supplements numerous other specific anti-avoidance provisions [hereinafter, “SAAPs”] of the Income Tax Act and, therefore, is a provision of last resort after the ... Continue Reading

Killing two taxes with one RPGA RPGs are “rocket propelled grenades”. As powerfully and precise as they may penetrate a wall of steel, not even they can pierce the almighty corporate veil, which supposedly separates the legal personalities of both shareholder and the corporate person being “held”. What can pierce the corporate veil, however, are the tax benefits that accrue to shareholders who corporately “bonus out” and then personally participate in ... Continue Reading

Introduction: Audits, Objections, and Tax Court

The “appeal process” is the term commonly used to refer to all stages available to a taxpayer to dispute a reassessment of their Notice of Assessment for a given tax year, which is often the result of a desk audit—as opposed to a field audit—(as is in  the case of tax shelters). In fact, the “appeal process” comprises three ... Continue Reading