Tax cases of interest

I presented “Tax Cases of Interest” at the CRA’s quarterly Tax Practitioner’s Consultation Group meeting at the Royal Botanical Gardens this morning.

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…

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Appeal quashed

In Cole v R, 2024 TCC 64, [1] The Appellant spent the better part of ten years trying to convince the Minister of National Revenue to remove over $240,000 added to her taxable income for the 2011 taxation year. Due…

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Demands for information from non-residents

Canada (National Revenue) v. Schreiber, 2024 FC 729, the Federal Court held that, in general, the CRA is entitled to demand information from non-resident persons or entities.

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Dissolved trust year-end

At the 2024 CALU conference round table (question 12, addressed in 2024-1005851C6), the CRA confirmed that a bare trust has a December 31 year-end and that a trust (other than a GRE) that dissolves during a calendar year still has…

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…

Appeal quashed

In Cole v R, 2024 TCC 64, [1] The Appellant spent the better part of ten years trying to convince the Minister of National Revenue to remove over $240,000 added to her taxable income for the 2011 taxation year. Due…

Continue reading…

Demands for information from non-residents

Canada (National Revenue) v. Schreiber, 2024 FC 729, the Federal Court held that, in general, the CRA is entitled to demand information from non-resident persons or entities.

Continue reading…

Dissolved trust year-end

At the 2024 CALU conference round table (question 12, addressed in 2024-1005851C6), the CRA confirmed that a bare trust has a December 31 year-end and that a trust (other than a GRE) that dissolves during a calendar year still has…

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…

Appeal quashed

In Cole v R, 2024 TCC 64, [1] The Appellant spent the better part of ten years trying to convince the Minister of National Revenue to remove over $240,000 added to her taxable income for the 2011 taxation year. Due…

Continue reading…

Demands for information from non-residents

Canada (National Revenue) v. Schreiber, 2024 FC 729, the Federal Court held that, in general, the CRA is entitled to demand information from non-resident persons or entities.

Continue reading…

Dissolved trust year-end

At the 2024 CALU conference round table (question 12, addressed in 2024-1005851C6), the CRA confirmed that a bare trust has a December 31 year-end and that a trust (other than a GRE) that dissolves during a calendar year still has…

Continue reading…