Income Tax Act s.164(6) Death can trigger a large capital gain under the deemed disposition rules. But what if the estate later sells assets at a loss? Parliament anticipated this mismatch. Under ITA s.164(6), an estate may elect to carry…
When someone passes away, the emotional impact is immediate. The tax consequences follow quickly. Under Canadian tax law, death is treated as a deemed disposition of most capital property. That means: The Income Tax Act treats the deceased as having…
– ITA s.163(2) | CRA VDP Framework You forgot to report foreign income. You never filed T1135. You missed several years of returns. Then you realize the exposure is not just tax. It is penalties. And in serious cases, gross…
– ITA s.220(3.1) You filed late. Interest accumulated. Penalties were assessed. Then someone tells you: “CRA can cancel penalties.” Yes — but not automatically. Under Income Tax Act (ITA) s.220(3.1), the Minister has discretionary authority to waive or cancel penalties…
You meant to file on time. You were waiting on a slip. You assumed there would be no penalty because “no tax is owing.” Then the Notice of Assessment arrives — with penalties and interest. Under Income Tax Act (ITA)…
ITA s.3, s.9, s.38, s.9; CRA Guide T4037; 2025 TCC 185 Cryptocurrencies don’t come with tax labels. They come with transactions — and Canada’s tax rules determine how those transactions are treated. For Canadian tax purposes, the big question every…
You worked in the United States. You accumulated savings in a 401(k). You moved back to Canada — or plan to. Then the question arises: “How is my U.S. 401(k) taxed in Canada?” The answer depends on: Your residency status…
– ITA s.126 You earned U.S. dividends. You sold foreign shares. You paid withholding tax overseas. Then you ask: “Do I have to pay tax on this again in Canada?” If you are a Canadian resident, the answer is: Yes…
– ITA s.128.1 | CRA Form NR73 You have accepted a role abroad. You are relocating your family. You plan to “move for a few years.” Then someone says: “Be careful — Canada taxes you when you leave.” They are…
If you are a Canadian resident who owns shares in a foreign corporation, the reporting obligation may go beyond Form T1135. Once ownership crosses certain thresholds, a far more detailed disclosure regime applies: Form T1134 – Information Return Relating to…