Tax Bytes

Look out for third-party civil penalties

This publication examines a revised circular from the Canada Revenue Agency (CRA) that expands the circumstances in which it may apply third-party penalties, and the potential implications for those promoting tax planning strategies that appear to offer certain advantages to taxpayers. Download now

June 11, 2026|Categories: Publications and reports, Tax Bytes|

Calmusky revisited

This Tax Byte discusses a recent Ontario Supreme Court decision – Kunka Estate v. Giasson – which confirmed that beneficiary designations on registered plans (such as TFSAs and RRIFs) are testamentary dispositions not subject to the presumption of a resulting trust. The Court rejected the controversial 2020 Calmusky v. Calmusky ruling which had sent tremors through the insurance and estate planning community in Ontario. The publication concludes with CALU’s advice to advisors in dealing with matters involving the presumption of resulting trust, and an alternate way to provide certainty for estate planners and their clients. Download now ...

May 20, 2026|Categories: Publications and reports, Tax Bytes|

Bill C-31 – Items of interest

This Tax Byte highlights items of interest to CALU members from Bill C-31, A second Act to implement certain provisions of the budget tabled in Parliament on November 4, 2025, which was introduced in the House of Commons on May 6, 2026. The legislation implements measures announced in Budget 2025, as well as technical tax changes included in draft legislation released in August 2024 and August 2025. Download now

May 13, 2026|Categories: Publications and reports, Tax Bytes|

Singleton planning lives on despite GAAR changes

This publication discusses the impact of recent changes to the general anti-avoidance rule (GAAR) on Singleton planning arrangements. While concerns have been raised in the tax community that Singleton arrangements might be challenged by the Canada Revenue Agency (CRA) in the future, a recent technical interpretation appears to deal with this concern. Download now

January 28, 2026|Categories: Publications and reports, Tax Bytes|

Keystone decision and the Capital Dividend Account (CDA)

This Tax Byte discusses a recent court decision involving the Keystone corporation that paid an excess capital dividend to its individual shareholders. The decision reinforces the need for owners of private corporations (and their tax advisors) to properly determine their capital dividend account (CDA) balance before the payment of any capital dividends. Download now

January 15, 2026|Categories: Publications and reports, Tax Bytes|

CRA warns Canadians about tax scheme involving insurance

This publication focusses on a recent “Tax Tip” from the Canada Revenue Agency (CRA) on the use of certain financial arrangements involving critical illness insurance that may be designed to avoid paying taxes. It discusses CALU’s work on this issue and provides advice to those with clients who have participated in (or may be contemplating) this type of arrangement. Download now

December 10, 2025|Categories: Publications and reports, Tax Bytes|

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