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Tax Perspectives

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Please note that these publications may not be up-to-date as taxation matters are subject to frequent changes.


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Summer 2005
Volume 5, Number 1

    The information in Tax Perspectives is prepared for general interest only. Every effort has been made to ensure that the contents are accurate. However, professional advice should always be obtained before acting and TSG member firms cannot assume

  • Introduction
    By Michael Cadesky, FCA, TEP
    Cadesky and Associates LLP (Toronto)

    This edition of Tax Perspectives discusses Canadian and international tax matters relevant to our clients and associates. Articles focus on dealing with the Canada Revenue Agency (CRA) as well as selected international matters. We are pleased to...

  • Tax Planning — Why Bother?
    By Michael Cadesky, FCA, TEP
    Cadesky and Associates LLP (Toronto)

    Sometimes people are reluctant to consider tax planning ideas. It is suggested that the exercise is too complicated, expensive, or risky. "The government will not like and will challenge it" is a common complaint, usually accompanied by "you can't fight...

  • Dealing With the Canada Revenue Agency ("CRA")
    By Hugh Woolley, CA
    Lewis and Company (Vancouver)

    One's success in dealing with a CRA audit can depend on the approach taken. Several years ago I read Stevie Cameron's book, "Blue Trust," about the life of prominent Montreal tax lawyer, Bruce Verchere. The book fascinated me so much that I decided to...

  • Madeira — Some Canadian Tax Planning Possibilities
    By Arnold Sherman, CA, CTA, TEP, FCA (England and Wales)
    H. Arnold Sherman Professional Corporation (Calgary)

    Where is Madeira? It is an island in the Atlantic Ocean, about 900 km south of Lisbon, off the coast of Morocco. Madeira (population — 250,000) is an integral part of Portugal — just as Newfoundland is an integral part of Canada. Madeira has...

  • Voluntary Disclosures — Should I or Shouldn't I?
    By Ralph H. Green, CA, TEP
    Ralph H. Green & Associates

    It is not uncommon for a taxpayer to discover a mistake in filing a return or inadvertently fail to report income. If subsequently audited by CRA and the mistake or omission discovered, the taxpayer may be subjected to significant penalties. While no one...

  • Profile: David M. Sherman, LLB, LLM

    David Sherman is a tax lawyer and one of Canada's best-known authors on income tax and GST. His Practitioner's Income Tax Act (published by Carswell) is widely recognized as the leading Income Tax Act in Canada due to his commentary and annotations. His...

  • R&D — Some Developments

    Now is a good time to discuss both the old news and the new developments about the SR&ED program in Canada. The old news is that a lot of corporations for one reason or another still do not claim the federal and provincial tax credits that are...

  • In Brief
    By Howard L. Wasserman, CA, CFP, TEP
    Cadesky and Associates LLP (Toronto)

    FIE — Non-Resident Trust RulesThe long awaited legislation on Foreign Investment Entities ("FIEs") and Non-Resident Trusts was released on July 18, 2005. It is to apply retroactive to January 1, 2003. The rules are similar to the...