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Author: John Loukidelis

Paletta: The Pusuit of Profit

Posted on: June 23, 2022 Last updated on: June 23, 2022 Written by: John Loukidelis
The author writes: Based on the Tax Court’s finding that Paletta’s trading activity was carried on solely for tax purposes without any pursuit of profit, the FCA concluded that Paletta’s trading activity could not constitute a source of business income,…
Continue reading “Paletta: The Pusuit of Profit”…

Collins Family Trust

Posted on: June 22, 2022 Last updated on: June 23, 2022 Written by: John Loukidelis
Here’s the final word from the Supreme Court on rectification and rescission. Shorter SCC: Don’t send us tax-related cases; we don’t like them. Canada (Attorney General) v Collins Family Trust, 2022 SCC 26 On appeal from the BCCA, were the…
Continue reading “Collins Family Trust”…

Recent developments in s 160 law

Posted on: June 11, 2022 Last updated on: June 11, 2022 Written by: John Loukidelis
Yves St-Cyr and Jacob Yau “What’s New in Section 160” 2021 Ontario Tax Conference Table of Contents 1. Introduction 2. Overview of Section 160 2.1. Purpose 2.2. Requirements for Application 3. Underlying Tax Debt and Burden of Proof 3.1. Challening…
Continue reading “Recent developments in s 160 law”…

Pipeline gotcha

Posted on: June 3, 2022 Last updated on: June 3, 2022 Written by: John Loukidelis
Clause 256(7)(a)(i)(D) provides that control of a corporation is not acquired only because a particular person who acquired the shares from an estate that arose on and as a consequence of the death of an individual, if the estate acquired…
Continue reading “Pipeline gotcha”…

Corporate attribution tips

Posted on: May 11, 2022 Last updated on: May 4, 2022 Written by: John Loukidelis
The authors summarize some methods for avoiding or mitigating corporate attribution: The corporate attribution rules do not apply where the transferee is a small business corporation. The transferor could consider effecting a freeze using a stock dividend. (But will the…
Continue reading “Corporate attribution tips”…

ITA election amendments

Posted on: May 9, 2022 Last updated on: May 4, 2022 Written by: John Loukidelis
In Glenogle Energy Inc. v Canada (Attorney General), 2022 FC 198, the taxpayer filed a 97(2) election with a nominal agreed amount. Three months later, the taxpayer applied to amend the election to insert an agreed amount of $32 million.…
Continue reading “ITA election amendments”…

Post mortem pipeline gone wrong

Posted on: May 7, 2022 Last updated on: May 4, 2022 Written by: John Loukidelis
In Robillard (Succession) c R, 2022 CCI 13, an estate completed a pipeline for a corporation within seven months of the death of its shareholder. The CRA applied 84(2) to the pipeline. The taxpayer appealed. The Court, after criticizing Canada…
Continue reading “Post mortem pipeline gone wrong”…

Underused Housing Tax Act

Posted on: May 4, 2022 Last updated on: May 4, 2022 Written by: John Loukidelis
Bill C-8 will enact the Underused Housing Tax Act (the “UHT Act”). The UHT Act will impose an annual tax equal to 1% of the value of certain residential properties. There are steep penalties for failing to file the associated…
Continue reading “Underused Housing Tax Act”…

Voluntary disclosure gone awry

Posted on: April 26, 2022 Last updated on: April 26, 2022 Written by: John Loukidelis
In Grewal v Canada (National Revenue), 2020 FC 356, the taxpayer, as part of a voluntary disclosure (VD), reported the existence of certain loans but (only implicitly?) took the position that they were not relevant to his income under the…
Continue reading “Voluntary disclosure gone awry”…

Form matters for an ABIL

Posted on: April 23, 2022 Last updated on: April 21, 2022 Written by: John Loukidelis
In Dias v R, 2021 TCC 85, the taxpayers unsuccessfully argued that loans that appeared to be to a numbered company had actually been made to corporations that might have been small business corporations (the numbered company was not). The…
Continue reading “Form matters for an ABIL”…
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Paletta: The Pusuit of Profit

The author writes: Based on the Tax Court’s finding that Paletta’s trading activity was carried on solely for tax purposes without any pursuit of profit, the FCA concluded that Paletta’s trading activity could not constitute a source of business income,…
Continue reading “Paletta: The Pusuit of Profit”…

Collins Family Trust

Here’s the final word from the Supreme Court on rectification and rescission. Shorter SCC: Don’t send us tax-related cases; we don’t like them. Canada (Attorney General) v Collins Family Trust, 2022 SCC 26 On appeal from the BCCA, were the…
Continue reading “Collins Family Trust”…

Recent developments in s 160 law

Yves St-Cyr and Jacob Yau “What’s New in Section 160” 2021 Ontario Tax Conference Table of Contents 1. Introduction 2. Overview of Section 160 2.1. Purpose 2.2. Requirements for Application 3. Underlying Tax Debt and Burden of Proof 3.1. Challening…
Continue reading “Recent developments in s 160 law”…

Pipeline gotcha

Clause 256(7)(a)(i)(D) provides that control of a corporation is not acquired only because a particular person who acquired the shares from an estate that arose on and as a consequence of the death of an individual, if the estate acquired…
Continue reading “Pipeline gotcha”…

Corporate attribution tips

The authors summarize some methods for avoiding or mitigating corporate attribution: The corporate attribution rules do not apply where the transferee is a small business corporation. The transferor could consider effecting a freeze using a stock dividend. (But will the…
Continue reading “Corporate attribution tips”…

Recent Posts

Paletta: The Pusuit of Profit

The author writes: Based on the Tax Court’s finding that Paletta’s trading activity was carried on solely for tax purposes without any pursuit of profit, the FCA concluded that Paletta’s trading activity could not constitute a source of business income,…
Continue reading “Paletta: The Pusuit of Profit”…

Collins Family Trust

Here’s the final word from the Supreme Court on rectification and rescission. Shorter SCC: Don’t send us tax-related cases; we don’t like them. Canada (Attorney General) v Collins Family Trust, 2022 SCC 26 On appeal from the BCCA, were the…
Continue reading “Collins Family Trust”…

Recent developments in s 160 law

Yves St-Cyr and Jacob Yau “What’s New in Section 160” 2021 Ontario Tax Conference Table of Contents 1. Introduction 2. Overview of Section 160 2.1. Purpose 2.2. Requirements for Application 3. Underlying Tax Debt and Burden of Proof 3.1. Challening…
Continue reading “Recent developments in s 160 law”…

Pipeline gotcha

Clause 256(7)(a)(i)(D) provides that control of a corporation is not acquired only because a particular person who acquired the shares from an estate that arose on and as a consequence of the death of an individual, if the estate acquired…
Continue reading “Pipeline gotcha”…

Corporate attribution tips

The authors summarize some methods for avoiding or mitigating corporate attribution: The corporate attribution rules do not apply where the transferee is a small business corporation. The transferor could consider effecting a freeze using a stock dividend. (But will the…
Continue reading “Corporate attribution tips”…

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Archives

Categories

Recent Posts

Paletta: The Pusuit of Profit

The author writes: Based on the Tax Court’s finding that Paletta’s trading activity was carried on solely for tax purposes without any pursuit of profit, the FCA concluded that Paletta’s trading activity could not constitute a source of business income,…
Continue reading “Paletta: The Pusuit of Profit”…

Collins Family Trust

Here’s the final word from the Supreme Court on rectification and rescission. Shorter SCC: Don’t send us tax-related cases; we don’t like them. Canada (Attorney General) v Collins Family Trust, 2022 SCC 26 On appeal from the BCCA, were the…
Continue reading “Collins Family Trust”…

Recent developments in s 160 law

Yves St-Cyr and Jacob Yau “What’s New in Section 160” 2021 Ontario Tax Conference Table of Contents 1. Introduction 2. Overview of Section 160 2.1. Purpose 2.2. Requirements for Application 3. Underlying Tax Debt and Burden of Proof 3.1. Challening…
Continue reading “Recent developments in s 160 law”…

Pipeline gotcha

Clause 256(7)(a)(i)(D) provides that control of a corporation is not acquired only because a particular person who acquired the shares from an estate that arose on and as a consequence of the death of an individual, if the estate acquired…
Continue reading “Pipeline gotcha”…

Corporate attribution tips

The authors summarize some methods for avoiding or mitigating corporate attribution: The corporate attribution rules do not apply where the transferee is a small business corporation. The transferor could consider effecting a freeze using a stock dividend. (But will the…
Continue reading “Corporate attribution tips”…

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