Carl Deeprose (Toronto)

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Shareholder Loans: The Interplay of 80.4, 15(2) and 20(1)(j) of the Income Tax Act

By Carl Deeprose (Toronto) and Alexandra David on November 5, 2020 Posted in Tax

Subject to certain exceptions, where a shareholder (other than a corporation resident in Canada) of a corporation is indebted to the corporation (a “Shareholder Loan”), the shareholder is deemed by subsection 80.4(2) to receive an interest benefit to the extent that the notional interest on the Shareholder Loan, calculated at the prescribed rate, exceeds the … Continue reading

Non-resident employees: withhold on worldwide income?

By Carl Deeprose (Toronto) on May 9, 2019 Posted in Employment and labour, Tax

ITA regulation 102 requires employers to withhold tax on remuneration paid to non-resident employees who are employed in Canada. This requirement can be avoided by seeking a treaty-based waiver (regulation 102 waiver) or certification as a qualifying non-resident employer. However, often there is not sufficient time to do this before the employment is to begin, or there … Continue reading

Tax competition is coming – review of the Federal Fall Economic Update

By Carl Deeprose (Toronto) on December 27, 2018 Posted in Tax

On November 20, 2018, the federal Government of Canada released their Fall Economic Update – a review of the country’s finances and economic health that addresses trends and changes taking place in Canada and the world since the federal Budget in the spring. Of particular note in 2018 was the anticipated response to the U.S. … Continue reading