UHT Traps – Loukidelis PC

It appears that the underused housing tax (UHT) might apply to residential property owned by

a partnership one of the partners of which is another partnership
a trust where one or more of the beneficiaries of the trust is another trust or a partnership
a corporation that is wholly-owned by a trustee who is neither a citizen nor permanent resident of Canada even if all of the beneficiaries of the trust are citizens or permanent residents

Alex Kerslake “Traps in the Underused Housing Tax: Tiered Ownership Structures” 12:4 Canadian Tax Focus (November 2022)

Deemed proceeds of an asset

In 0808414 B.C. Ltd. v R, 2024 TCC 99, the taxpayer sold equipment to a non-arm’s length purchaser as part of a transaction that also transferred employees and obligations under a pension and benefits plan. The CRA reassessed on the…

Trust beneficiary liability under s 160

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Minister accepts VD but then reassesses other years anyway

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