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Have COVID-19 Travel Restrictions Affected Your Tax Residency?

By: Boris Stanislav, Associate and Felix Wu, Associate , Farber Tax Law

The COVID-19 pandemic has undoubtedly had a considerable impact on the international tax regime with regard to tax regency. Canada’s test for tax residency primarily revolves around either a calculation of days (i.e. sojourning) or through residential ties. In consideration of our new realities, the CRA released and continues to update its guide to international income tax issues.

The uncertain future of the Tax Court of Canada’s Practice Note No. 23 “Preliminary Ruling Docket” in the new COVID-19 reality

By Milosz Zak, Associate, and Boris Stanislav, Associate, Farber Tax Law

On December 12, 2019, the Tax Court of Canada introduced “Practice Note No. 23: Preliminary Ruling Docket Procedure” – a pilot project intended to provide parties with a non-binding opinion of a Tax Court judge. The Tax Court heavily circumscribed what kinds of appeals may be eligible for the Preliminary Ruling Docket.

Day Traders Receiving CERB: Audits are Coming

By Selena Ing, Associate and Felix Wu, Associate, Farber Tax Law

The Federal Government instituted the Canada Emergency Response Benefit (the “CERB”) to provide temporary financial support to workers who have stopped working as a result of COVID-19. However, the CRA will likely be reviewing the returns of CERB recipients and asking those who weren’t qualified to repay the amounts received with interest and, in some cases, penalties.

Sections 212 and 216 of the Income Tax Act: Examining Tax Obligations Arising from Non-Residents Earning Rental Income from Canadian Properties

By Felix Wu, Associate and Andy Yip, Articling Student, Farber Tax Law

Under Canada’s self-reporting tax system, taxpayers often assume that they are required to submit tax returns only when they earn income. However, it is important to note that unique circumstances may given rise to obligations in reporting and in tax even when an individual is a payer.