Non-resident corporations that have no activity in Canada during its fiscal year are not required to file a Canadian corporate tax return. However, without filing a Canadian corporate tax return, the Canada Revenue Agency (CRA) will not know that you did not have activity in Canada. Therefore, CRA may send you a letter requesting that a return is required to be filed.

If CRA requests that a return be filed, even though your company had no activity in Canada, you may be tempted to file a return in order to be in compliance. Read More

Canada Revenue Agency (CRA) has a number of dates and deadlines of importance to corporations. Failure to comply with these deadlines may raise a red flag with CRA, which in turn may trigger an audit.

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John Richardson, capital gains tax, principal residence

The price of Toronto real estate continues its upward trajectory. This morning I met with yet another (who could have known) Canadian resident who wishes to renounce U.S. citizenship. This person is completely compliant with his U.S. tax obligations. He is renouncing for a very common reason.

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Larry Stolberg

It is my understanding that the Canada Revenue Agency (“CRA” Canada) has not changed it’s position on the deductibility on interest incurred on borrowing to fund the redemption of shares or the payment of dividends.

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Grant Gilmour

The Canada Revenue Agency (CRA) has issued me a business number. Now what do I do?

In Canada, once a company is assigned a business number then it needs to request which type of program account it needs to be setup. There are five types of accounts:

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Grant Gilmour

Tax Question:

When is my deadline to file my corporate tax return, and if I miss the deadline, what are the consequences?

Facts:

All companies have six months from the end of their fiscal year to file their T2 corporate tax return.

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Larry Stolberg

The T1134 and T1135 are a sample of Canadian foreign information returns such as the U.S. 8938, 5471, or 8865.

A number of Canadians are investing in the U.S. real estate market with a U.S. limited partnership, whose limited partners are solely Canadian residents and the general partner is a U.S. C corporation, whose shareholders are also Canadian residents.

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Larry Stolberg

The Canadian Income Tax Act provides a time period in which one may appeal a Notice of Assessment (NOA) or Reassessment. It is not unusual for a taxpayer not to have received the NOA. Although the taxpayer should advise Canada Revenue Agency of any change in addresses or to correct an incorrect address on file, this case was decided on the premise of the lack of communication to the taxpayer of CRA’s assessment of tax payable for a taxation year.

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Grant Gilmour

Are the aggressive collection calls you have been getting from the Canada Revenue Agency (CRA) real? The short answer is NO. The calls are a scam. Please read on.

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Grant Gilmour

Shares in a corporation can be participating or non-participating, among other features. Participating shares are eligible to “participate” in the equity growth of the company and be permitted to receive dividends. Non-participating shares do not benefit from the equity growth of the company. This can potentially impact the valuation of shares.

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Many Americans hold interests in income-producing properties in Canada. In many cases, when they acquire them, they do not obtain proper advice regarding the Canadian tax implications and requirements.

This can be quite costly-in the absence of following certain procedures, an American resident earning rents from Canadian real estate can be subject to a 25% Canadian tax on GROSS rents (that is, no deduction for related expenses). This can apply even if no profit is being earned from renting the property.

As a general rule, a non-resident who earns rents for the use of Canadian real estate is subject to 25% tax on the gross rents under Part XIII of the Income Tax Act (“the Act”). This Read More