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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 [...]

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 [...]

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 [...]

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 [...]

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 [...]

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 [...]

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 [...]

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 [...]

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 [...]

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 [...]