Canada: Tax

Robinson v Canada (Attorney General), 2026 FC 854 (Federal Court File No. T-1567-22) [Robinson] is a significant Federal Court decision for taxpayers, accountants, and advisors managing cross-border residence disputes

Foreign companies and investors evaluating opportunities in Canada must consider how tax planning affects deal economics, financing flexibility, cash repatriation, treaty access and exit value. The structure and financing of an investment can significantly impact returns, flexibility and the ability to execute future growth plans, making early attention to these issues critical to avoid unnecessary cost and complexity.

US citizens moving to Canada face unique tax challenges as they remain subject to IRS obligations while becoming Canadian tax residents. From TFSA reporting traps and PFIC complications to estate planning with non-citizen spouses, understanding the cross-border implications before relocating can prevent costly compliance failures and optimize your dual-country tax position.

Cryptocurrency has become a significant source of wealth for many Canadians. Whether an individual holds Bitcoin as a long-term investment, actively trades digital assets, participates in staking programs, or engages in decentralized finance (DeFi), cryptocurrency can create unique estate planning challenges that do not arise with traditional investments.

Understanding the various types of trusts available in Canada is essential for effective estate planning and asset management. From family trusts and alter ego trusts to qualified disability trusts and bare trusts, each structure offers distinct advantages for tax planning, probate avoidance, and protecting beneficiaries with special needs. This comprehensive overview examines the key requirements, uses, and tax implications of common trust structures to help you determine which option best suits your estat

Canadians with US property, rental income, or extended winter stays face specific IRS reporting requirements that go far beyond simple tax residency rules. Understanding which forms to file, when to file them, and how FIRPTA withholding, the Substantial Presence Test, and cross-border tax credits interact can mean the difference between routine compliance and costly penalties.

A taxpayer who discovers years of unreported income, unfiled returns, or missing foreign-information forms will usually ask one urgent question: how far back can the CRA go? Under the current Voluntary Disclosures Program, there is no single answer.

The sale of a business, usually operated through a corporation, can be structured as either a share sale or an asset sale, and the two are legally and practically distinct. In a share sale, the vendor sells the corporation’s shares to the purchaser, so that the purchaser acquires control of the corporation’s assets indirectly through share ownership.

If you hold units or shares of an offshore hedge fund, a foreign investment company or any other non-resident fund that reinvests its income instead of paying it out, the CRA may be able to tax you every year on income you never received.

If you are a Muslim homebuyer weighing a halal mortgage against a conventional one, the product that keeps you offside your faith may still put you offside the taxman in ways a conventional mortgage never would.

Canada's transfer pricing rules, first introduced in 1997, have historically imposed disproportionate compliance costs on smaller businesses while primarily serving large multinational enterprises. New draft regulations released in July 2026 introduce a simplified documentation regime specifically designed to reduce transfer pricing complexities for smaller Canadian businesses, while maintaining the existing penalty framework.

Canada's new Productivity Mega Deduction promises to slash the marginal effective tax rate on business investment to just 6.4%, positioning the country as the most competitive G7 nation for capital deployment. This permanent tax incentive extends immediate expensing to roughly 65% of capital assets, fundamentally reshaping the economics of investing in Canadian operations across manufacturing, energy, technology, and resource sectors.