Canada: Income Tax

Canadian taxpayers, including content creators, influencers, and digital entrepreneurs, who earn income from digital marketing activities—including online advertising through platforms such as Google AdSense, promotional services linked to NFT projects, and sponsorship arrangements with offshore entities—often assume that this income is not subject to GST/HST or is automatically zero-rated because it involves non-Canadian counterparties.

Section 160 of the Income Tax Act (ITA) is one of the most potent collection tools available to the Canada Revenue Agency (CRA). While most tax liabilities are personal to the individual who earned the income, section 160 creates a form of “derivative” or secondary liability.

When a taxpayer misses the deadline to file a notice of objection to a CRA tax reassessment, the situation often feels irreversible. In practice, however, the law does provide a pathway to correct that mistake — but only if the process is followed precisely.

On February 20, 2026, the Federal Court of Appeal (FCA) released its decision in Canada v. DAC Investment Holdings Inc. (DAC), 2026 FCA 35, overturning the Tax Court of Canada’s (TCC) ruling that a corporate continuance used to exit the Canadian-controlled private corporation (CCPC) regime did not amount to abusive tax avoidance.

Permanent establishment Canada analysis has become increasingly complex due to the OECD’s 2025 remote work guidance. Remote work permanent establishment Canada risk is now a central concern for businesses operating across borders and provinces.

Canadian tax appeals processes can involve lengthy wait times and unclear communication from authorities, but when action is required, deadlines become suddenly urgent.

Les régimes d’unités d’actions différées (« UAD ») constituent une forme de rémunération fondée sur des titres de capitaux propres pour les employés...

Canadian taxpayers are currently afforded a cumulative lifetime exemption on capital gains realized from the sale of qualified small business corporation shares and on a qualified farm property or a qualified fishing property.

Canada’s trust reporting framework has undergone significant reform in recent years as part of broader efforts to improve tax transparency and prevent tax avoidance through undisclosed beneficial ownership arrangements.