Tax Alert

Tax Alert

May 15, 2013

Voluntary Disclosures

There has been much discussion in recent months of tax avoidance and evasion. The March 2013 Federal Budget proposes to introduce the Stop International Tax Evasion Program, which would reward individuals (up to 15% of federal tax collected) who provide tips on significant international tax non-compliance leading to collection of outstanding federal taxes in excess of $100,000.

April 15, 2013

Discretionary Shares: Are they under attack?

Discretionary shares are a popular income-splitting tool for professional corporations and owner-managed corporations. They have gained popularity since the Neuman decision from the Supreme Court of Canada in 1998 (Melville Neuman v. Her Majesty the Queen). Not surprisingly, the Canada Revenue Agency (CRA) is still looking for ways to attack the use of discretionary shares.

March 28, 2013

Canada Revenue Agency GST/HST audit activities

For small businesses (generally businesses with annual sales of less than $4 million), the CRA has implemented a new audit approach whereby, instead of combined income tax and GST/HST audits, the agency will conduct separate audits. In our experience, the CRA’s increased focus has prompted auditors to focus on GST/HST issues previously overlooked during the combined tax audits era.

February 22, 2013

Interest Deductibility

At some point in the lives of most individuals and business enterprises, loan interest becomes a significant annual expenditure. Not surprisingly, its deductibility in computing income has been the subject of many disputes between taxpayers and the Canada Revenue Agency (CRA).