Canada: Tax

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‘Deemed Disposition’ Of All Your Assets At Death: Tax Planning For Canadian Business Owners With High-Net-Worth Estates
Canada does not generally impose a separate inheritance tax on beneficiaries. That does not mean death is tax-free. Under subsection 70(5) of the Income Tax Act, a Canadian taxpayer is generally deemed to dispose of each capital property at fair market value immediately before death, unless a specific rollover or other relieving rule applies.
Canada Tax
RS
Rotfleisch & Samulovitch P.C.
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Article
Bare Trust Reporting In Canada: Where The Rules Stand, Which Arrangements Are Caught, And Who Must File For 2026
After years of uncertainty and last-minute relief, Canada's bare trust reporting rules have finally been settled through Bill C-15. The new regime exempts most family arrangements while requiring commercial structures like nominee corporations and joint ventures to file detailed beneficial ownership disclosures starting with the 2026 taxation year. Understanding which arrangements are caught, which are exempt, and what steps to take now is essential for compliance before the March 31, 2027 filing deadline.
Canada Tax
MT
Miller Thomson LLP
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Curated
‘Deemed Disposition’ Of All Your Assets At Death: Tax Planning For Canadian Business Owners With High-Net-Worth Estates
Canada does not generally impose a separate inheritance tax on beneficiaries. That does not mean death is tax-free. Under subsection 70(5) of the Income Tax Act, a Canadian taxpayer is generally deemed to dispose of each capital property at fair market value immediately before death, unless a specific rollover or other relieving rule applies.
Canada Tax
RS
Rotfleisch & Samulovitch P.C.
See more
Article
Draft Technical Amendments Expand The Scope Of Taxable Canadian Property
The Canadian government has proposed significant technical amendments to the Income Tax Act's definition of "taxable Canadian property" (TCP), fundamentally altering how publicly traded partnership units are classified and expanding the look-through rules for determining TCP status. These changes, effective upon Royal Assent, will impact cross-border transactions and investment structures by broadening the scope of what constitutes TCP and reinstating historical rules for options and interests in property.
Canada Tax
BL
Borden Ladner Gervais LLP
Article
Mesures de simplification de la documentation ponctuelle en matière de prix de transfert
Le ministère des Finances canadien propose un régime simplifié facultatif pour la documentation des prix de transfert qui pourrait alléger la charge administrative des contribuables admissibles. Quels sont les critères d'admissibilité et les exigences d'analyse qui s'appliqueraient aux entreprises souhaitant bénéficier de ce nouveau cadre réglementaire? Les propositions législatives publiées en juillet 2026 définissent cinq points essentiels que le
Canada Tax
BC
Blake, Cassels & Graydon LLP
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