Tag Archive for Canada

Canadian Tax FAQ – CRA Program Accounts

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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Long-Term Debt On A Balance Sheet

Grant Gilmour

What is Long-Term Debt on a Balance Sheet?

The Long-Term Debt category appears as a long-term liability on a Balance Sheet. The balance represents the total outstanding balances of all bank loans, mortgages and financial contracts.

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Canadian Tax Help – Deferred Revenue On Balance Sheet

Grant Gilmour

What is Deferred Revenue on a Balance Sheet?

The Deferred Revenue section appears under current liabilities on a Balance Sheet. Deferred Revenue represents revenue that is usually received in advance for future goods and services.

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Canadian Tax – Government Taxes Payable On Balance Sheet

Grant Gilmour

What are Government Taxes Payable on a Balance Sheet?

The Government Taxes Payable category appears under Current Liabilities on a Balance Sheet as it is expected that the amounts owing will be paid within one year. It represents funds that a company has an obligation to pay to government bodies such as Canada Revenue Agency (CRA).

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Accounts Payable On A Balance Sheet – Canada Tax

What are Accounts Payable on a Balance Sheet?

The Accounts Payable category appears under Current Liabilities on a Balance Sheet, as it is expected that these amounts owing will be paid within one year. It represents funds that a company has an obligation to pay vendors or creditors for goods and services received.

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Tax Residency In Canada: Deemed VS. Factual Resident

John Richardson

Tax Residency is becoming an increasingly important topic. Every country has its own rules for determining who is and who is not a “tax resident” of that country. The advent of the OCED CRS (“Common Reporting Standard”) has made the determination of “tax residence” increasingly important.

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Brad Rolph, Senior Economist—Transfer Pricing Seminar—July 18

Kat Jennings

Brad Rolph is a Partner at Grant Thornton LLP in Toronto. He is one of Canada’s leading transfer pricing experts and was the first economist hired by any of the Big Four accounting firms in Canada to practice exclusively in the area of transfer pricing.

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US Citizens Pensioners Please Note

US citizens residing in Canada are not taxable on their US social security for US tax purposes in accordance with Article XVIII of the Canada/U.S. tax treaty. The country of residence taxes the other countries social security payments to 85%. Likewise CPP or OAS from Canada is excluded on the US 1040 if you reside in the US. If the particular social security payment is included in a country’s tax return, generally the maximum income inclusion is 85% to the taxable income computation.

The foregoing also  applies to part-year residents which would require using these concepts.

Many returns are incorrectly prepared not recognizing this treaty provision generally resulting is additional tax paid more so for those in higher marginal tax bracket due to significant other sources of income subject to tax. Read more

Personal Services Provided In The United States

Individual contractors from Canada providing services in the U.S. in the capacity of self-employed individuals or utilizing their Canco should be aware that depending on the number of days present and percentage of U.S. gross business income, Article V, paragraph 9 of the Canada/U.S. Tax Treaty may deem them or Canco to have a permanent establishment in the United States. This stems from the 2007 Protocol that in this respect was effective commencing in 2010.
Since 2010, this means that income will be subject to U.S. taxation requiring the filing of U.S. federal and possibly State returns, however foreign tax credit is available on the Canadian tax return.

Previously, independents had to demonstrate that they were not carrying on business in the U.S. through a Read more

Part 2: Why Justice Martineau’s Decision Has Handed @ADCSovereignty The Framework For Ultimate Victory – The Importance of “Staying The Course”

Introduction – what this post is about …

I attended the hearing in Vancouver, B.C. on August 4, 5 2015. At that time I wrote a group of posts (here and here) discussing my perception of the hearing. Those posts included expressions of my opinion that Justice Martineau was highly engaged, was working hard on understanding the issues, and was affording all parties a fair hearing. Although, disappointed with his decision (handed down on September 16, 2015), and not agreeing with his conclusions, I reaffirm my sentiments in the previous posts.

This post is more about the “system” than it is about Justice Martineau specifically. In a judicial system, it is possible for “reasonable people” to have “reasonable Read more

Part 1: Justice Martineau Provides @ADCSovereignty The Only Thing Worse Than A Root Canal

This post is Part 1 of my thoughts on Justice Martineau’s decision.

I  left my root canal appointment this afternoon to a message announcing that Justice Martineau had rendered his decision. We did not win round 1. Notice that I did NOT say that the Government won round 1.

Here is the decision:

T-1736-14 decision sept-16-2015

Before, I comment specifically on the decision, I want to be clear on the following points: Read more

Special Election For U.S. Expats In Canada With S Corporations Can Avoid Double Tax

Often, U.S. citizens who move to Canada are shareholders of U.S. S Corporations. This can potentially create double tax problems.

Under Canadian tax law, the S Corporation is just like any other foreign corporation. Dividends received are generally fully taxable. In addition, if the S Corporation is a “controlled foreign affiliate”, the shareholder can be taxable on his or her share of underlying investment income and capital gains under Canada’s “foreign accrual property income” (“FAPI”) rules.

Double taxation can arise because of the fact that Canada will generally only grant limited foreign tax credit relief for the U.S. taxes paid by the shareholder on the S Corporation Read more