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Archive for Income Tax

Tax Challenges For Divorced Parents – Why?

Annette Nellen

We get used to certain rules in the tax system and then think they HAVE to be there. But, often, that is not the case. I think the rules related to divorce are good examples.

Alimony is deductible by the payer and taxable to the recipient. This violates the “fruit of the tree” doctrine from the famous 1930 US Supreme Court case, Lucas v Earl.

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Small Business Inter-Corporate Dividends

Larry Stolberg

Revisions to Section 55 of the Income Tax Act (“ITA”) may prevent the tax-free payment of inter-corporate dividends within a related corporate group.

With the exception of Part IV tax where applicable, the related party exemption per S55(3)(a) will no longer be available to allow cash dividends say paid from Opco to Holdco unless there is safe income in the payor corporation at the time of the dividend payment.

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Does Small Revenue Loss Justify Bad Tax Law? No

Annette Nellen

More on legislative efforts to give a tax break to winning Olympians(!) …

See my post, “Olympic Medal Taxation Craziness“, for background. This post got a lot of comments both here and on Tax Connections.

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Income Tax Aspects Of Non-Business Capital Gains And Losses Part II

Harold Goedde

This article will discuss the tax implications for wash sales stock rights, gifts, small business stock, non-business bad debts, and inheritances. This is a the second article in a series of three focusing on gains and losses. (Read Part I here)

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How Many Times To Tax Business Income?

Annette Nellen

A recent post (8/26/16) on the Tax Justice website was titled – Why We Must Close The Pass-Through Loophole? That caught my attention as I was trying to think what the “loophole” might be? A loophole is a provision that can be used beyond its intended purpose because the rule is not written specifically enough. When a rule is being used as intended, it is not a loophole. For example, sometimes the mortgage interest deduction is called a loophole, but it is not. People deducting interest on the mortgages on their primary and vacation homes is using the rule as intended.

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Income Tax Aspects Of Non-Business Capital Gains And Losses Part I

Harold Goedde

This article will discuss the general aspects of capital gains and losses, the brokers reporting to investors, how and where they are reported on Form 1040 and supporting schedules.

It is advantageous to have investment income in the form of long-term (held longer than one year) capital gains (LTCG) because they are taxed at a lower rate than ordinary income. For 2016, the net LTCG will be taxed at various rates depending on the tax bracket:

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Olympic Medal Taxation Craziness

Annette Nellen

Every four years we usually see at least one bill introduced in Congress to make Olympic medals and related prize winnings (such as cash) non-taxable to the athletes. Why? There is no good reason for excluding this prize income. All prizes are taxable because they are an accession to wealth which is what our income tax system is based upon. If you win a raffle or win on Jeopardy!, the prizes are taxable.

Why should an Olympic medal be different?

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3 “Must Haves” Of Tax Provision Software For Small & Medium Businesses

Stephen Day

Recently published surveys indicate that 50% to 70% of the tax departments in publicly traded companies exclusively use spreadsheets to manage ASC 740 processes. However, the percentage would be higher if the surveys focused strictly on small and medium businesses (SMB). These numbers have held steady the scrutiny of the last fifteen years relative to the tax areas of financial statement reporting and internal controls. The current provision offerings have not met the needs of SMB tax executives. If a technology solution wants to be an answer to the homegrown spreadsheets running the ASC 740 process, it must be accurate and comprehensive while being easy to use.

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Building Value Is The Win-Win Of Exit Planning

Ron Oddo

In all likelihood, you are absolutely critical to the success of your business. Without you, there is no business.

We want to fix that.

With a little luck and a lot of hard work, we can help you become an Inconsequential Owner. Having said that, perhaps a bit of explanation is in order.

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Sending Non-Canadian Resident Employees To Canada

Larry Stolberg

Regulation 102 of the Income Tax Act (ITA) requires payroll withholding on income derived by virtue of employment. This applies to, say, a U.S. employer sending its employee to Canada to work on an assignment. Withholding would include income tax and contributions to the Canada Pension Plan (CPP) and Employment Insurance (EI).

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Start-up And Organization Costs

John Stancil

When starting a business, the owners are likely to incur two classes of costs that are not normally encountered in the ongoing operations of the business and should not be included as operating expenses. These are start-up expenditures and organization costs. Each of these are specifically defined and receive special tax treatment.

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Calculating Multi-Jurisdictional Income Tax In Canadian Provinces

Grant Gilmour

If your company is a Canadian taxpayer, Canadian corporate tax is calculated by allocating taxable income between the provinces in which your company has a permanent establishment presence.

Discussion:

 

The company is considered to have a permanent establishment presence in any Canadian province where any of the following conditions are met:

  • A fixed place of business such as an office, branch, warehouse, workshop or factory in the province.
  • An agent or an employee present in the province.
  • The company owns land in the province.
  • There is substantial use of machinery or equipment by the company in the province.

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