Border crossings

Article Abstract:

Proposed amendments to the US-Canada income tax treaty has been approved in the Legislature, making it the third amendment since the treaty was signed in 1980. The amendments extend the tax exemption of Canadians who die owning real property in the US from $60,000 to $600,000. There will also be bigger deduction for direct spousal transfers of properties for Canadians, but not in excess of the amount stated in the unified credit for marital bequests. Meanwhile, Canada will allow Canadians who die to avail of tax credits equal to any US estate tax paid for their estate for a US property.

Property Taxes, Transfer taxes, Real property tax, Real property taxes, Double taxation

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See the spot hedge: time for Revenue Canada to catch up with accounting practice

Article Abstract:

New and varied financial instruments have complicated tax accounting in Canada, and a lack of specific laws and guidelines have compounded the problem. The effectiveness of hedges is questionable due to the uncertainties concerning their tax treatment. The vagueries of Canada's Income Tax Act make it hard to diferrentiate between capital gains and losses and income gains and losses, leaving open the possibility that hedges will not be given the same tax treatment as the underlying transactions.

Analysis, Tax accounting, Financial instruments

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No more "wait and see": when it comes to transfer-pricing documentation, Revenue Canada's revised Form T106 means the day of reckoning has arrived

Article Abstract:

Revenue Canada's revised Form T106 for reporting non-arm's-length transactions with non-residents is considered. Under the new regulations, related party transactions must reflect arm's-length terms and conditions.

Tax Law, Transfer pricing

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