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Tax and Accounting

    Archives

    Author Archive for: "MAtlas"
    By Michael Atlas
    In Alerts, News
    Posted January 22, 2019

    Canadian Tax Issues with Capital Dividends and Non-Resident Shareholders

    Under the Income Tax Act (“the Act”) a “capital dividend” (“CD”)[1] paid by Canadian resident corporation is not included in the income of a recipient shareholder. A CD is an actual or deemed [...]

    READ MORE
    By Michael Atlas
    In Alerts, News
    Posted September 18, 2018

    LLC “Checking the Box” May Have Pitfall for Canadians!

    An answer to Question 16 of the “CRA Roundtable”, that was part of the 20th Annual STEP Canada Conference held earlier this year, may lead taxpayers and their advisors to make a dangerously [...]

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    By Michael Atlas
    In Alerts, News
    Posted September 12, 2018

    CRA Cracking Down on Non-Residents Claiming CCB

    In the vast majority of cases where I advise individuals in connection with tax residency issues, it is with the objective of ensuring that they cease to be residents of Canada (or remain [...]

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    By Michael Atlas
    In Alerts, News
    Posted August 31, 2018

    Beware – The CRA is Scrutinizing Canadians with Offshore Trusts

    A recent lunch with a tax lawyer friend of mine gave me some valuable insights regarding how tough and aggressive the Canada Revenue Agency is getting with Canadians who report substantial [...]

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    By Michael Atlas
    In Alerts, News
    Posted August 10, 2018

    How a Canadian Holdco Can Reduce Taxation of FAPI

    As a general rule, every Canadian resident who is a shareholder of a “controlled foreign affiliate” (“CFA”), will be subject to tax in Canada on that person’s share of the “foreign accrual [...]

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    By Michael Atlas
    In Alerts, News
    Posted July 27, 2018

    Recent Federal Court of Appeal Decision May Help Canadian Trusts with Foreign Beneficiaries

    In a recent article that I posted on my Canadian International Tax Blog (http://taxca.com/blog-2018-5/) (“Canadian Trusts with Foreign Beneficiaries Face New Challenges”), I discussed certain [...]

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    By Michael Atlas
    In Alerts, International Tax, Tax, Wolters Kluwer
    Posted July 3, 2018

    Most of Canada’s Tax Treaties Will Get An Instant Rewrite Due To MLI

    On May 28, 2018, Canada’s Finance Minister tabled a Notice of Ways and Means Motion aimed at introducing legislation to enact the Multilateral Convention to Implement Tax Treaty Related Measures [...]

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    By Michael Atlas
    In Alerts, International Tax, Tax, Wolters Kluwer
    Posted June 25, 2018

    Little-Known Provision in Treaty Can Ensure That Americans Get Foreign Tax Credit for Canadian Taxes

    The ability to claim credits for foreign taxes (“foreign tax credits”) (“FTC”) is the most fundamental and common way of avoiding double tax in connection with cross-border transactions. Both [...]

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    By Michael Atlas
    In News
    Posted January 31, 2018

    New Canadian Tax Regime for Combating Income Splitting Does Not Apply to Payments to Non-Residents

    Michael Atlas is a Toronto-based Chartered Professional Accountant who practices as an independent consultant on high-level Canadian tax matters, with particular emphasis on international tax [...]

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    By Michael Atlas
    In News
    Posted October 5, 2017

    Tax Considerations for Non-Residents Using Canadian LPs

    Michael Atlas is a Toronto-based Chartered Professional Accountant who practices as an independent consultant on high-level Canadian tax matters, with particular emphasis on international tax [...]

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