Resources

Welcome to Alejandro Fiszman's Resource Center. Here, you'll find valuable insights and practical guidance on tax-related issues. The articles cover topics to help you navigate tax challenges, stay informed on best practices, and make confident decisions about your finances.

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Dividend Gross-Up & Integration: A Practical Guide for Owner-Managers

New semester, new notebooks-and for Canadian law students stepping into tax, few topics repay early study like dividend integration. For owner-managers (and the students who will soon advise them), understanding how Canada grosses up dividends and then credits back corporate tax is table stakes for smart remuneration and corporate housekeeping.

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Navigating CERB and CRB Disputes

The COVID-19 relief benefits were intended to support workers during lockdowns that closed businesses. However, for many self-employed Canadians, this assistance has led to ongoing disputes with the Canada Revenue Agency (CRA). These audits often affect freelancers, gig-economy workers, and small-business owners, whose income can vary. The disputes frequently involve complex rules, such as whether to use net or gross self-employment income, or how to prove a 50 percent reduction in average weekly earnings.

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Understanding butterfly reorganizations for business owners with multiple companies

For entrepreneurs who have built multiple businesses under one corporate umbrella, the butterfly reorganization offers a sophisticated solution for dividing assets among shareholders without triggering immediate tax consequences. This corporate restructuring technique, while complex in execution, provides significant value for business owners seeking to separate their various enterprises or prepare for succession planning.

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Understanding estate freeze transactions for business owners

An estate freeze allows business owners to lock in their company's current value while passing future growth to the next generation. This tax planning strategy helps entrepreneurs preserve wealth within their families while maintaining control of their businesses during their lifetime.

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Living Will versus POAPC: two very different tools

Clients frequently ask how a Power of Attorney for Personal Care (“POAPC”) works and why lawyers recommend it instead of (or in addition to) a “living will.” This article explains:

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The DIY Tax Software Filing Trap

Tax season tempts Canadians with the promise of quick refunds, yet filing remains complex. DIY software like TurboTax markets simplicity and savings—but recent Ontario reassessments show the hidden costs, especially for families claiming provincial credits.

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Moving to Canada: Basic U.S. Tax Facts

If a U.S. citizen decides to give up their citizenship and move to Canada, they need to be aware of significant tax consequences under U.S. law (IRC § 877A).

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US ETF and Cryptocurrency Basics

As a Canadian investing in U.S.-based ETFs and cryptocurrencies, it's crucial to understand the associated tax implications to ensure compliance and optimize your returns. When you receive dividends from U.S. ETFs, a 15% withholding tax is applied if you submit IRS Form W-8BEN

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Taxes When Leaving Canada

When you move out of Canada, you need to understand how your taxes will be affected.

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Case National R&D Inc. v. The Queen (2020)

National R&D Inc. v. The Queen, the Tax Court of Canada examined the eligibility of a software development project for a Project Tracking System (PTS) under the Scientific Research and Experimental Development (SR&ED) tax credit program.

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Capital Gains Exemptions and Trusts

If you’re a Canadian business owner looking to sell your company or plan your estate, using trusts and capital gains exemptions can be a valuable strategy.

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