RESIDENCY OF A TRUST – A QUESTION OF MANAGEMENT AND CONTROL II: A View from the CRA Bridge!

Tuesday, February 9th, 2016

Last fall I wrote about the Supreme Court of Newfoundland and Labrador being asked to rule on the specific issue of residency which would have significant tax implications to the trust depending on the Court’s determination. In Discovery Trust vs Canada (National Revenue), 201201G6615, at issue was whether a trust was ...

STATUTE-BAR ASSESSMENTS AND RELIANCE ON OTHERS

Tuesday, January 26th, 2016

Pursuant to the provisions of the Income Tax Act, the Canada Revenue Agency (“CRA”) has a three-year time frame within to reassess a taxation year, commencing with the date of the original Notice of Assessment. Beyond the three-year limit, returns are referred to as statute-barred. Nevertheless, the CRA can always reassess ...