Articles

Section 85 of the Income Tax Act is a commonly used provision that permits the tax exempt transfer of property to a corporation. This paper provides an overview of the application of the section covering key topics including the general rules of section 85, eligible property, consideration or “boot,” anti-abuse rules, requisite filings and other…

This paper argues that North American Free Trade Agreement (NAFTA) renegotiation and amendment should be used to define and restrict domestic tax provisions improperly used as indirect trade subsidies or tariffs. In doing so the Canadian foreign affiliate rules and the proposed US border adjustment tax are examined. Download the full paper here: Nick Wright…

This paper explains how to use the Canada-Barbados Tax Treaty to avoid Canadian tax on international business income. Download the full paper here: Nick Wright Canada Barbados Tax Treaty Controversy & Reform 161228 This article and the contents herein are for informational purposes only and do not constitute legal advice. Readers are advised to seek…

This paper provides an overview of relevant tax considerations when a Canadian resident is purchasing US real estate and discusses different ways to structure a purchase to minimize tax exposure. Download the full paper here: Nick Wright Tax Considerations when Purchasing American Real Estate 160906 This article and the contents herein are for informational purposes…