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Non-Arm’s Length and Section 84.1 in Poulin v. The Queen, 2016 TCC 154

Canada - November 3 2016 The so-called “anti-surplus stripping rule” in section 84.1 of the Income Tax Act (Canada) can apply where an individual taxpayer transfers shares of…

Managing The Audit of Real Estate Transactions

Canada - October 11 2016 It used to be that the favorite topic of conversation in Vancouver, and then more recently in Toronto was the cost of real estate. There was unending…

Greg DelBigio, Q.C., Noah Sarna

CRA Releases New Income Tax Folio on Prohibited Investments - RRSPS, RRIFs and TFSAs

Canada - September 6 2016 On September 2, 2016, the CRA released new Income Tax Folio S3-F10-C2, Prohibited Investments - RRSPs, RRIFs and TFSAs, which discusses the…

CRA Releases New Income Tax Folio on Income Tax Reporting Currency

Canada - September 6 2016 On September 2, 2016, the CRA released new Income Tax Folio S5-F4-C1 Income Tax Reporting Currency, which discusses functional currency tax reporting…

CRA Releases New Income Tax Folio on Qualified Investments - RRSPS, RESPs, RRIFs, RDSPs and TFSAs

Canada - September 6 2016 On September 2, 2016, the CRA released new Income Tax Folio S3-F10-C1, Qualified Investments-RRSPs, RESPs, RRIFs, RDSPs and TFSA, which discusses…