It is my understanding that CRA 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.
Subparagraph 20(1)(c) (i) of the Income Tax Act (“ACT”) requires that the borrowed funds be used for earning income from business or property. The exception to the direct use of borrowed funds, is premised on the basis…read more
Renunciation of U.S. citizenship is an expatriation event requiring the filing of IRS Form 8854 with your tax return for year of expatriation. Renunciation has a fee of US$2,350.
Renunciation is voluntary and requires an appointment for receiving a certificate of loss of nationality. In March 2016, all renunciation applications go to the American Citizen Services Unit in Vancouver for screening and review before an appointment is set at one of the U.S. consulates. It…read more
Similar to the U.S. rules, Canada may tax personal services provided in Canada by U.S. persons who are not residents of Canada income tax purposes. The provisions governing this are regulations 102, 105 and section 115 of the Income Tax Act (‘ITA”).
The treaty-employment income
Article XV of the Canada/U.S. tax treaty may exempt from Canadian taxation, personal services that is employment income where the income is not more than $10K earned in the source country…
On October 3, 2016 changes were announced to the computation of the available principal residence exemption. Changes were made to properties held by individuals and to properties held by trusts. Discussion below is limited to the changes affecting individuals. Changes to trust is more complex and may be addressed in another BLOG.
Simply put, the PRE is a formula that exempts all or a portion of the otherwise computed gain on the disposition. The numerator…read more
Prior to 2016, it was CRA’s administrative practice that the disposition of your principal residence was not reportable where the entire gain is exempt. There have been a few court cases where the administrative practice was not upheld because CRA Form T2091 was not filed.
Effective for the 2016 taxation year, all dispositions of a principal residence need to be reported even though the entire gain may be exempt from taxation. Schedule 3 of the…read more
For donations of $200 or less, the federal refundable tax credit is 15%. For donations more than $200, the federal refundable tax credit is representative of the top marginal tax rate of 29% even if you were not in that marginal tax bracket.
With the introduction of the top federal marginal rate of 33% on taxable income over $200,000, it was presumed that the refundable tax rate on donations more than $200 would be 33%.