Shareholder loans

I just posted a brief introduction to shareholder loans, which introduction you can find here.

TFSA trading business

Canadian Western Trust Company v. Canada, 2024 FCA 108, affirmed 2023 TCC 17, which had confirmed assessments issued to a TFSA because, the CRA had alleged, it had engaged in a securities trading business.

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Section 160 taxpayer win

In Vasilkioti v R, 2024 TCC 101, the Court held that section 160 did not apply in respect of a transfer of real property from a husband to the appellant-wife because the CRA did not adequately prove the husband’s underlying…

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2024 STEP Roundtable Part 2

In response to question 10, the CRA referred to Maurice Kissel Family Trust v R (unreported 2019-4092(IT)G). The trust in question prohibited the distribution of amounts to a “designated beneficiary”, but the trust purported to allocate and deduct gains it…

Continue reading…

Trust allocations

Fiducie Historia c HMK, 2024 CCI 76 (French only), affirmed the validity of trust allocations made by trustees where, the CRA alleged, another agreement (entered into to preserve capital losses in a corporation controlled by the trust) seemed to give…

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2024 STEP Roundtable

The following is based on the text published in Tax Topics 2713 (September 10, 2024). Question 1 – Spousal Trusts A spousal trust that receives a contribution of capital after the death of the spouse-beneficiary remains a spousal trust, but…

Continue reading…

TFSA trading business

Canadian Western Trust Company v. Canada, 2024 FCA 108, affirmed 2023 TCC 17, which had confirmed assessments issued to a TFSA because, the CRA had alleged, it had engaged in a securities trading business.

Continue reading…

Section 160 taxpayer win

In Vasilkioti v R, 2024 TCC 101, the Court held that section 160 did not apply in respect of a transfer of real property from a husband to the appellant-wife because the CRA did not adequately prove the husband’s underlying…

Continue reading…

2024 STEP Roundtable Part 2

In response to question 10, the CRA referred to Maurice Kissel Family Trust v R (unreported 2019-4092(IT)G). The trust in question prohibited the distribution of amounts to a “designated beneficiary”, but the trust purported to allocate and deduct gains it…

Continue reading…

Trust allocations

Fiducie Historia c HMK, 2024 CCI 76 (French only), affirmed the validity of trust allocations made by trustees where, the CRA alleged, another agreement (entered into to preserve capital losses in a corporation controlled by the trust) seemed to give…

Continue reading…

2024 STEP Roundtable

The following is based on the text published in Tax Topics 2713 (September 10, 2024). Question 1 – Spousal Trusts A spousal trust that receives a contribution of capital after the death of the spouse-beneficiary remains a spousal trust, but…

Continue reading…

TFSA trading business

Canadian Western Trust Company v. Canada, 2024 FCA 108, affirmed 2023 TCC 17, which had confirmed assessments issued to a TFSA because, the CRA had alleged, it had engaged in a securities trading business.

Continue reading…

Section 160 taxpayer win

In Vasilkioti v R, 2024 TCC 101, the Court held that section 160 did not apply in respect of a transfer of real property from a husband to the appellant-wife because the CRA did not adequately prove the husband’s underlying…

Continue reading…

2024 STEP Roundtable Part 2

In response to question 10, the CRA referred to Maurice Kissel Family Trust v R (unreported 2019-4092(IT)G). The trust in question prohibited the distribution of amounts to a “designated beneficiary”, but the trust purported to allocate and deduct gains it…

Continue reading…

Trust allocations

Fiducie Historia c HMK, 2024 CCI 76 (French only), affirmed the validity of trust allocations made by trustees where, the CRA alleged, another agreement (entered into to preserve capital losses in a corporation controlled by the trust) seemed to give…

Continue reading…

2024 STEP Roundtable

The following is based on the text published in Tax Topics 2713 (September 10, 2024). Question 1 – Spousal Trusts A spousal trust that receives a contribution of capital after the death of the spouse-beneficiary remains a spousal trust, but…

Continue reading…