New Deeming Rules for US Permanent Establishments
Wednesday, November 10th, 2010
Effective for 2010, new deeming rules have been introduced in the Fifth Protocol of the Canada-US Income Tax Treaty. Companies providing services in the United States should take note of these new rules as the rules deem a non-resident who provides services in the United States to have a permanent establishment where certain conditions are [...]
An open letter to the Ombudsman for Taxpayers’ Rights
Tuesday, February 9th, 2010
Annette Silva, CA We contacted CRA today concerning a refund of GST relating to a return that was electronically filed on January 4, 2010. The company has one transaction each year that relates to an inter-company charge whereby one company pays the GST and the other common-ownership sister-company has an offsetting input tax credit. Apparently [...]
Accounting Standards for Private Enterprises
Saturday, February 6th, 2010
Steve Myers, CA On December 16, 2009, the Accounting Standards Board (AcSB) released the final Accounting Standards for Private Enterprises. This marked the culmination of three years of discussion, feedback and input from Canadian Institute of Chartered Accountants (CICA) members, users of financial statements and standard setters. This task was made necessary largely due to [...]
Ask A Tax Expert
Wednesday, January 20th, 2010
Paul F. Keul, CA Question: I am looking into investing in some property in Orlando. I wanted to know what the tax implications are when the property is sold in the future. What are the capital gains taxes in the U.S for foreign investors as well as the tax costs in Canada when the funds [...]
Extracting Profits From Your Corporation
Wednesday, January 20th, 2010
Curtis T. Link, CA, CFP, TEP Most of us are familiar with the strategy to bonus down each year at the fiscal year end of the company to ensure full access to the small business rates of corporate tax. This is a general “rule of thumb” that is appropriate in many, but not all, circumstances. [...]
