A difficult case: when is an Intangible Expenditure a Capital Expense?

September 14, 2017 | George Evans

On April 24, 2017, the Tax Court of Canada rendered its judgment in Armour Group Ltd. v. The Queen. This case grapples with whether the taxpayer's land transactions with the Province of Nova Scotia resulted in deductible business income or a...

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When is a non-resident corporation carrying on business in Canada?

September 6, 2017 | Seth Lim

In the leading case of Maya Forestales S.A. v. The Queen, 2005 TCC 66, the Tax Court of Canada analyzed whether a non-resident corporation was carrying on business in Canada such that it would be liable to pay tax on its taxable income earned in...

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Our new Section 85 Navigator

August 30, 2017 | Mat Armstrong

We are excited to introduce Tax Foresight’s new navigator: T2057: Section 85 Election Eligibility. The T2057 navigator assesses whether a disposition of property by a taxpayer to a taxable Canadian corporation is eligible for an election under...

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Introducing the new Directors' Liability Classifier

August 24, 2017 | Kelsey Horning

We are excited to introduce Tax Foresight’s new classifier: Directors’ Liability. The Directors’ Liability Classifier assesses a director’s liability by evaluating whether the due diligence defence is available, pursuant to s. 227.1(3) of the ...

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Tax Foresight & Case Finder creating big impact

August 16, 2017 | George Evans

Law and accounting firms across Canada are buzzing: Tax Foresight and Case Finder are revolutionizing tax law research. Our users are working smarter and more efficiently than ever, spending less time digging through keyword and boolean searches...

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When are gains from trading in securities taxable as business income?

August 9, 2017 | Seth Lim

On April 21, 2017, the Tax Court of Canada rendered its judgment in Foote v. The Queen, 2017 TCC 61. As Tax Foresight correctly predicted with 95%+ confidence, the Court held that the taxpayer’s gains from trading in securities should be...

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When is land purchase a current expense?

August 1, 2017 | Kelsey Horning

In the leading case of Johns-Manville Canada Inc. v. The Queen , [1985] 2 SCR 46, the Supreme Court of Canada set the standard for whether tangible expenditure is a current or capital What can we learn from this key decision? Our Tax Foresight...

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Condo sale: business income or capital gain?

July 27, 2017 | George Evans

In Feizmohammadi v. The Queen, 2017 TCC 28 the Tax Court of Canada held that the taxpayer’s condominium sale constituted income from a business. Tax Foresight correctly predicts the outcome of the Feizmohammadi case with 91% confidence.

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Are mortgage payments shareholder benefits?

July 19, 2017 | Seth Lim

On May 29, 2017, the Tax Court of Canada rendered its judgment in Struck v. The Queen, 2017 TCC 94, holding that the taxpayer’s corporation had conferred a shareholder benefit on the taxpayer by making mortgage payments for his personal residence.

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When is a TFSA not tax-free?

July 7, 2017 | Kelsey Horning

The Canada Revenue Agency recently confirmed their concern about non-passive investments in TFSAs. When might this be an issue?

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