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Missed T1134 foreign-affiliate filings can create significant penalties even where no additional Canadian tax is owing. This guide explains when CRA’s VDP may help, how T1134 penalties work, what must be reconstructed, and why a complete foreign-affiliate review matters.
Is an adult child on an elderly parent’s joint bank account a bare trust for 2026? See when a T3 applies and how the $50,000 and $250,000 exceptions work.
CRA’s Voluntary Disclosures Program is materially more accessible under the rules in effect for applications received on or after October 1, 2025. This 2026 guide explains prompted and unprompted applications, penalty and interest relief, T1134/T1135 and GST/HST disclosures, eligibility, documentation periods and the risks of getting the process wrong.
When a corporation holds registered title to real estate for another owner, the 2026 bare trust rules may require a T3 and Schedule 15. See how the exceptions apply.
Certain bare trusts are back in Canada’s trust-reporting regime for 2026, with a March 31, 2027 filing deadline for most calendar-year arrangements. This detailed guide explains the new two-gate test, the $50,000 and $250,000 exceptions, common family and real-estate situations, filing mechanics and penalties.
A parent added to title so an adult child can get a mortgage may fall within the new 2026 principal-residence exclusion. Learn when a T3 is and is not required.
A taxpayer who relocated from Canada to another treaty country continued filing Canadian resident returns for years. After reconstructing the full residency history, Lepore & Company concluded there was a strong basis for treating the taxpayer as a non-resident for the relevant prior years, prepared amended filings and a detailed technical submission, and — after CRA requested and received further information — had its residency and treaty position accepted. CRA reassessed the relevant years, refunding the client more than $100,000 of Canadian income tax. The outcome was specific to this taxpayer’s facts and is not a precedent.
CRA refused further relief from a T1135 late-filing penalty, relying partly on the very failure the taxpayers were asking relief for. On judicial review of that refusal — not of the penalty assessment itself — the Federal Court in Kaur v. Canada (Attorney General) found the reasoning circular and sent the request back to CRA for redetermination. The Court did not cancel the penalty, and CRA may still refuse relief. Here’s what the decision establishes for anyone facing a T1135 penalty or a refusal of relief.
In Stern v. The King, 2026 TCC 131, the Tax Court accepted brokerage records, foreign tax information slips, and credible testimony as sufficient evidence to support a..
No — but not for the reason often assumed. In Somerset Limited v. The King, 2026 TCC 123, the Tax Court held that Somerset remained a Canadian-Controlled..