Comedy Platinum out of Toronto - "Canada's Team" quest for the Cup

[mattola]

I mean, could they not have waited until the Bruins retired his jersey?!? 20 seasons in Boston, almost as loved as Bobby Orr in that town.

i 100% agree. If we won with Sundin I wouldn't want his Jersey retired as a Canuck. The whole thing was ludicrous.

 

[Bloody Brian Burke]

Scanning the schedule, I’m expecting a bad loss Saturday vs Ottawa and a shitcanning Sunday for Keefe.

Even if management thinks it’s a lost season for some insane reason they can’t just let these fucks walk all over them without repercussion for another two months.

 

[dash]

 

[dash]

 

[forty_three]

I guess I'm just not seeing the issue here. A big part of my job as bench coach is to schmooze the refs. I joke with them, talk with them, and when necessary yell at them.

 

[dash]

I guess I'm just not seeing the issue here. A big part of my job as bench coach is to schmooze the refs. I joke with them, talk with them, and when necessary yell at them.

Yeah, I posted it because I thought it was a funny gif and an odd reaction.

 

[puckhead]

Boy, that would be nice if we get to choose our own tax rates.

 

[forty_three]

Yeah, I posted it because I thought it was a funny gif and an odd reaction.

I made the mistake of reading the thread. Jeez.

CSB Time
At one of our games last season, I noticed one of the refs was a guy I had coached with in the past, but I didn't pay enough attention to the other. Jeff (the coach) came over to introduce himself and I made some comment about him watching out for our enforcer because "he's fucking nuts" and we laughed. Then he asked me if I saw who the other ref was. It was a kid who played for the team we both coached years ago, and we kind of had a rocky relationship with. Nate skated over, saw me and grinned. I said "you learn to skate backwards yet?" and he laughed and said "I was always faster than you, goalie boy'.

Kids on my bench were panicked at first that I was giving shit to the refs. It was actually a good game, because I could pull them both aside and discuss clearly whenever a WTF thing happened.

 

[Bloody Brian Burke]

This part has my curiosity:

Tavares argues the bonus should have been taxed at only 15 per cent under a provision of a Canada-U.S. taxation treaty, which sets the lower tax rate for “inducements,” such as signing bonuses, paid to athletes, artists, actors and musicians.

Anyone have any idea what this is supposed to mean because I couldn’t find shit about it on Google. Also what are these “taxes” were supposed to be paying? Is that a new thing?

 

[BGDave]

This part has my curiosity:

Tavares argues the bonus should have been taxed at only 15 per cent under a provision of a Canada-U.S. taxation treaty, which sets the lower tax rate for “inducements,” such as signing bonuses, paid to athletes, artists, actors and musicians.

Anyone have any idea what this is supposed to mean because I couldn’t find shit about it on Google. Also what are these “taxes” were supposed to be paying? Is that a new thing?

Great question, and without any knowledge of JTs personal taxes, let me take a shot at it

Tax rates under a tax treaty apply ONLY when there is a payment by one company (in this case MLSE) to a tax resident of the other country (JT). The 15% tax rate would apply only if (1) JT were a tax resident of the US at the time the payment was made and (2) he was NOT a Canadian tax resident in 2018.

Basically these rates are created to allow (in this case) Canada to tax a portion of the bonus he received even though he was (allegedly) not subject to Canadian taxes. So MLSE withheld 15% from his bonus and sent it to CRA.

By the way, the 15% is creditable against JTs US income tax.

If CRA is now saying the proper tax rate is 38%, what they are really saying is "JT, bruh, you were a Canadian tax resident in 2018 and as such we tax ALL of your income at FULL Canadian tax rates".

In effect, the real dispute is over whether JT is a Canadian tax resident in 2018.

So what is a Canadian tax resident? Being a Canadian citizen is NOT enough to make you a Canadian tax resident. Residency is determined based on your personal facts and is largely determined by where you lived that year {gross oversimplification}.

The first thing they look at to determine where you live is to look at the number of days you are physically present in Canada. If you are in Canada for 183+ days in the year, you will generally be considered a Canadian tax resident. Yes, they will pull passport scans to verify where you were


If you aren't in Canada for 183 days though, CRA can still look at other evidence to try to argue you are a Canadian tax resident.

 

[jstewismybastardson]

Boy, that would be nice if we get to choose our own tax rates.

Its why Torts maintained residency in Point Roberts when he coached the Canucks. I would have thought Tavares would have lived the majority of 2018 in the US to maintain his US residency for tax purposes but maybe he was too excited to return home to Toronto and pee in his childhood bedsheets

 

[BGDave]

Its why Torts maintained residency in Point Roberts when he coached the Canucks. I would have thought Tavares would have lived the majority of 2018 in the US to maintain his US residency for tax purposes but maybe he was too excited to return home to Toronto and pee in his childhood bedsheets

The facts will be conclusive, but for $8M I dont blame CRA for taking a shot....

 

[jstewismybastardson]

The facts will be conclusive, but for $8M I dont blame CRA for taking a shot....

For the CRA, to take this shot, I think they may already have the conclusive facts

 

[BGDave]

And since I am now all worked up about one of my favo(u)rite topics, the Canada-US tax treaty is meant to help people avoid taxation in both countries.

Another fun hypothetical: when I win the $1B Powerball down here, I will need a cooperative and trustworthy Canuck to help me exploit the provisions of the tax treaty. In the US, lottery winnings are taxable and with State taxes, looking at about a 45% total tax rate. A friendly Canadian who wins the lottery will be subject to only a 30% tax rate as mandated by the tax treaty. Of course, lottery winnings are not taxed in Canada, so 30% is the total tax bill. This extra 15% tax on $1B is about $150M, so when I win I will be looking for a Canuck to cash the ticket for me, pay the 30% tax and give me the net proceeds. For a fee of course.

 

[BGDave]

For the CRA, to take this shot, I think they may already have the conclusive facts

Facts like the peed in bedsheets?

 

[Bloody Brian Burke]

Great question, and without any knowledge of JTs personal taxes, let me take a shot at it

Tax rates under a tax treaty apply ONLY when there is a payment by one company (in this case MLSE) to a tax resident of the other country (JT). The 15% tax rate would apply only if (1) JT were a tax resident of the US at the time the payment was made and (2) he was NOT a Canadian tax resident in 2018.

Basically these rates are created to allow (in this case) Canada to tax a portion of the bonus he received even though he was (allegedly) not subject to Canadian taxes. So MLSE withheld 15% from his bonus and sent it to CRA.

By the way, the 15% is creditable against JTs US income tax.

If CRA is now saying the proper tax rate is 38%, what they are really saying is "JT, bruh, you were a Canadian tax resident in 2018 and as such we tax ALL of your income at FULL Canadian tax rates".

In effect, the real dispute is over whether JT is a Canadian tax resident in 2018.

So what is a Canadian tax resident? Being a Canadian citizen is NOT enough to make you a Canadian tax resident. Residency is determined based on your personal facts and is largely determined by where you lived that year {gross oversimplification}.

The first thing they look at to determine where you live is to look at the number of days you are physically present in Canada. If you are in Canada for 183+ days in the year, you will generally be considered a Canadian tax resident. Yes, they will pull passport scans to verify where you were


If you aren't in Canada for 183 days though, CRA can still look at other evidence to try to argue you are a Canadian tax resident.

Ah alright. Thought it was saying there’s some special tax class in place for entertainers or some shit that runs contrary to all the “high tax land” stuff that disadvantages Canada against most US jurisdictions.

Guess it could be as simple as since he signed on July 1 as of that date he was a Canadian resident and thus when the bonus was paid that’s 50% of the year so give moneys now?

 

[jstewismybastardson]

And since I am now all worked up about one of my favo(u)rite topics, the Canada-US tax treaty is meant to help people avoid taxation in both countries.

Another fun hypothetical: when I win the $1B Powerball down here, I will need a cooperative and trustworthy Canuck to help me exploit the provisions of the tax treaty. In the US, lottery winnings are taxable and with State taxes, looking at about a 45% total tax rate. A friendly Canadian who wins the lottery will be subject to only a 30% tax rate as mandated by the tax treaty. Of course, lottery winnings are not taxed in Canada, so 30% is the total tax bill. This extra 15% tax on $1B is about $150M, so when I win I will be looking for a Canuck to cash the ticket for me, pay the 30% tax and give me the net proceeds. For a fee of course.

I already have this arrangement with my brother and my sister in law lol

/and for the Canadians buying Powerball tickets ... if the ticket physically leaves the continental US, it is void ... so when I buy tickets I usually leave them at my relatives house ... doubt I ever hear from them again if its a winner

 

[jstewismybastardson]

Facts like the peed in bedsheets?

Probably ... he probably headed home right after Isles season ended to nuzzle in to them. Got bad advice ... his agent should have reminded him he should stay in Long Island and keep peeing in those bedsheets until after he signed with TO

 

[Bloody Brian Burke]

Anyway, I’m very excited to get my $100 grocery rebate.

 

[BGDave]

Ah alright. Thought it was saying there’s some special tax class in place for entertainers or some shit that runs contrary to all the “high tax land” stuff that disadvantages Canada against most US jurisdictions.

Guess it could be as simple as since he signed on July 1 as of that date he was a Canadian resident and thus when the bonus was paid that’s 50% of the year so give moneys now?

Could be. a position they can take. If so, they would have to get the IRS to agree, and ceasing residency in the US would have another set of complications. But hey, thats why we have tax lawyers.