Jonathan Garbutt

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An Open Letter To Harry & Meghan On The Tax Implications of Moving to Canada

Jonathan Garbutt 01/15/2020

What follows is a rough analysis of Harry and Meghan’s (The Duke and Duchess of Sussex’s) tax situation in Canada, the U.K. and United States. No actual business or client relationship with the Duke and Duchess of Sussex is inferred nor implied. Andersen Tax LLP has not ...

“Just Phoning It In,” Is Not Due Diligence For Directors

Jonathan Garbutt 12/01/2019

In Macdonald v. The Queen, the Tax Court of Canada recently ruled that the directors of a Canadian corporation were liable under section 217.1(1), for both its employee and employer deductions for the unremitted employment insurance premiums (EI) and Canada Pension Plan contributions (CPP), as ...

Going Toe to Toe with TOSI (Canada’s Tax on Split Income)

Jonathan Garbutt 01/01/1970

The federal government introduced the Tax on Split Income (“TOSI”) rules effective as of the start of 2018. The purpose of the rules was to prevent Canadian business owners from splitting their income in ways that were not available to salaried employees. For example, prior ...

Canadian Covid-19 Small Business Tax Relief; Much Ado About Nothing

Jonathan Garbutt 01/01/1970

The Canadian federal government has announced its response to the Covid-19 Pandemic and is implementing a number of measures to help the economy.[1] In terms of cost, the largest of these measures are designed to increase liquidity and help Canadian firms maintain access to credit ...

What is a Business? According to the Tax Court of Canada.

Jonathan Garbutt 01/01/1970

In two recent cases, the Tax Court of Canada dealt with the issue of “what is a business?” as opposed to a hobby, or something that is not quite yet a business. Callahan v. HMQ[1] and Hurwitz v. HMQ[2], were heard as informal procedure cases ...

Harsh Result of s. 160(1) of the Canadian Income Tax Act.

Jonathan Garbutt 01/01/1970

Canadian Tax Cases – Mamdani Family Trust and Subsection 160(1). The recent case of Mamdani Family Trust v. HMQ[1] illustrates the absolute nature of subsection 160(1)of the Income Tax Act (the “Act”). The Mamdami Family Trust (the “Trust”) is an inter vivos trust resident in ...

The member firms of Andersen in Canada focus on Canadian, international and Canada-U.S. cross-border tax matters. With offices across Canada, our tax professionals work with a broad range of businesses and individual clients to develop innovative tax solutions for a diverse range of issues. Our senior leaders and many of our professional staff have extensive experience in Canadian, international, U.S. and cross-border tax matters with major international accounting firms, as well as practical experience working with businesses and individuals.

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An Open Letter To Harry & Meghan On The Tax Implications of Moving to Canada

“Just Phoning It In,” Is Not Due Diligence For Directors

Going Toe to Toe with TOSI (Canada’s Tax on Split Income)

Canadian Covid-19 Small Business Tax Relief; Much Ado About Nothing

What is a Business? According to the Tax Court of Canada.

Harsh Result of s. 160(1) of the Canadian Income Tax Act.

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