Consider leaving your RRIF/RRSP to a child or grandchild that is financially dependent on you in their RDSP
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Consider leaving your RRIF/RRSP to a child or grandchild that is financially dependent on you in their RDSP
If you are a U.S. person potentially subject to this tax, but have not filed as such, contact us to discuss your options
Failing to make source deductions,
may expose directors personally to the liability
Deducting personal expenses in a corporation can lead to a very costly bill, as in Tax Court of Canada case, July 23, 2020
Claim amount increased to $23 from $17 per meal, for a total of $69/day
Taxability of unreported income all beyond the normal reassessment period- French Court of Quebec case, June 10, 2020.
U.S. Economic Impact payments and Canada Emergency Wage Subsidy program extension announcements
Consider whether starting CPP before, after, or at age 65, would be the most advantageous
The homepage is the most important page of your business’s website. It is the virtual shop front to your business, providing your customers a first impression of what you have to offer. You only have seconds to grab your customer’s attention so it is key to make sure that they can find what they’re looking for quickly and easily.
While you’re free to be creative with the design of your homepage, there are some standard items that a user will expect to see when they arrive at your website.
Branding can be in a name, sign, symbol, slogan, words or design, or a combination of these elements, that identify the products or services of your business and help you stand out from your competitors.
A call to action is an image or text that prompts your user to take some form of action.
A good site navigation will help customers to find the different areas in your website.
Typography is the visual component of the written word, the art and technique of arranging print.
Make your first impression count! A clean and appealing web design, which is easy to navigate and highlights the key points of your business, can better attract customers than a website full of irrelevant information. If your audience can’t identify what it is your business can offer, they won’t stick around.
In a June 21, 2017 French Technical Interpretation (2016-0678361E5, Seguin, Marc), CRA opined that a deemed gain due to a limited partner’s negative adjusted cost base (under Subsection 40(3.1)) could not be added to that limited partner’s capital dividend account. CRA opined that partnership income generally retains its nature and character when allocated out to partners.
DEBT FORGIVENESS – TIERED PARTNERSHIPS
When a commercial obligation is settled or extinguished for an amount less than the principal amount of the debt, Section 80 applies the debt forgiveness rules. CRA notes that the forgiven amount is applied to reduce “tax balances” or is included in the debtor’s income under Subsection 80(2) or (13).
Section 80 requires that the forgiven amount be applied in the following order:
After the mandatory application of the forgiven amount, the debtor may elect to apply the remaining forgiven amount to reduce the capital cost of depreciable property (Subsection 80(5)); cumulative eligible capital (Subsection 80(7)); resource expenditures (Subsection 80(8)); capital properties (Subsection 80(9)); certain shares and debts(Subsection 80(10)); certain shares, debts and partnership interests (Subsection 80(11)); and current year net capital losses (Subsection 80(12)). If there is still a residual balance, half of the amount will be added to the taxpayer’s income (Subsection 80(13)). The rules are modified slightly for partnerships.
In a March 22, 2017 Technical Interpretation (2016-0666481E5, Gibbons, Jim), CRA considered the impact of the debt forgiveness rules on a forgiven amount in a tiered partnership. While general comments were provided, CRA specifically opined on the implications where a bottom partnership (BP) is wound up into the top partnership (TP) in the same year a forgiven amount is included in the BP’s income(Subsection 8(13)).
CRA noted that the BP would have a deemed year-end immediately before the time it ceased to exist. Therefore, the BP’s income inclusion would occur in the deemed fiscal period, and, as a partner of the BP, the TP could deduct an amount in respect of the relevant limit which would then be deemed to be a commercial debt obligation that the TP issued and was settled at the end of the BP’s deemed fiscal period (Subsection 80(15)). The TP could then apply the forgiven amount to their own tax attributes (under Subsections 80(5) to (10)).
CRA also noted that the forgiven amount could only be applied against the adjusted cost base of the TP’s interest in the BP if the BP and theTP were not related (e.g. the TP only had a minority interest in the BP) under Subsection 80(9).
The balance of any forgiven amount, after applying Subsections 80(5) to (10), would be included in the TP’s income (Subsection 80(13)) and allocated to its members.
As the TP would be deemed (Subparagraph 80(c)(i)) to have issued a commercial debt obligation that was settled at the end of the BP’s deemed fiscal period, Subsection 8(15) would also apply to the partners. Thus, the partners would be able to claim a deduction (Subparagraph 80(15)(a)) up to the relevant limit which could then be treated as a forgiven amount and applied against the taxpayer’s own tax attributes