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Author: John Loukidelis (page 10)

REOP reborn?

Posted on: April 19, 2023 Last updated on: April 19, 2023 Written by: John Loukidelis
In Philip Friedlan and Adam Friedlan “Brown v. Canada: REOP Redux?” Tax for the Owner-Manager 23:2 (April 2023), the authors argue that Brown v R, 2022 FCA 200, appears to have confirmed that R v Paletta, 2022 FCA 86, introduced…
Continue reading “REOP reborn?”…

Travel expense case

Posted on: March 30, 2023 Last updated on: March 30, 2023 Written by: John Loukidelis
1048547 Ontario Inc. v R, 2023 TCC 24, illustrates the evidentiary burden a taxpayer will face when trying to justify travel expenses to exotic locations that seem to have nothing to do with the taxpayer’s ordinary business operations. If you…
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Accounting entries, again

Posted on: March 23, 2023 Last updated on: March 23, 2023 Written by: John Loukidelis
In Houle c. Le Roi, 2023 CCI 2, the Court considered assessments that alleged a shareholder received a benefit in two taxation year because of an (unsupported) increase in the credit balance of the shareholder loan account. The Court held…
Continue reading “Accounting entries, again”…

Safe income again

Posted on: March 9, 2023 Last updated on: March 6, 2023 Written by: John Loukidelis
A corporation must reduce the safe income of its shares by contingent liabilities and reserves, if they reduce the “inherent gain” of the shares. “The safe income is reduced by actual and potential cash outflows”. APFF 2022 Conference question 1,…
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RRSP spousal rollover

Posted on: March 8, 2023 Last updated on: March 6, 2023 Written by: John Loukidelis
An estate cannot transfer property from an RRSP to a former spouse on a rollover basis under 73(1) (which requires that the transferor be an individual other than a trust) or 146(8.1) (if the former spouse is not a beneficiary…
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Safe income determination time

Posted on: March 6, 2023 Last updated on: March 6, 2023 Written by: John Loukidelis
If Aco is incorporated to purchase the assets of Bco and then purchases the assets, Bco’s safe income is not increased by any gain realized on the sale if the incorporation of Aco triggers the safe income determination time. The…
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Poker Winnings Taxed

Posted on: February 24, 2023 Last updated on: February 24, 2023 Written by: John Loukidelis
Sometime ago, I wrote a post about the taxation of gains realized at the poker table. I said that the CRA might not be focusing on auditing poker players because the average player loses money. I quoted an article by…
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164(6) carry back procedure

Posted on: February 17, 2023 Last updated on: February 10, 2023 Written by: John Loukidelis
An estate that wishes to carry back a loss to the terminal return of the deceased under subsection 164(6) of the Income Tax Act (Canada) must file an amended T1 for the terminal year. A T1ADJ will not suffice. See…
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RDTOH and safe income

Posted on: February 17, 2023 Last updated on: February 17, 2023 Written by: John Loukidelis
The CRA accepts that, if refundable tax contributes to the gain on a share immediately before its disposition, it can also contribute to the safe income of the share. In the example, a corporation with a December 31 year-end, sells…
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Corporate guarantee of shareholder loan

Posted on: February 17, 2023 Last updated on: February 17, 2023 Written by: John Loukidelis
A shareholder of a corporation borrows money for an income-earning purpose, and the corporation guarantees the loan, which guarantee is secured by a mortgage on corporate-owned property. The shareholder pays a reasonable guarantee fee to the corporation. The shareholder is…
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Guest post on the DTC

The following article on the disability tax credit was written by Tanya O’Connell, a former law clerk at Loukidelis Professional Corporation. The Disability Tax Credit (DTC) The DTC is a personal tax credit available under section 118.3 of the Income…
Continue reading “Guest post on the DTC”…

Inter-company loans

Subsection 15(1) of the Income Tax Act could apply where Aco loans money to Bco and Bco has no means of repaying the money. On the other hand, subsection 246(1) will not apply where Bco and its shareholder have no…
Continue reading “Inter-company loans”…

Change in use and flipping

The CRA has confirmed that a deemed disposition under subsection 45(1) of the Income Tax Act resulting from a change in use is not a disposition for the purposes of the flipping rules in subsections 12(12) and 12(13). See 2024-1027831C6.
Continue reading “Change in use and flipping”…

Swiss bank account trouble

In Azmayesh-Fard v R, 2025 TCC 20, the Court considered whether the CRA had properly reassessed a taxpayer beyond the normal reassessment period and imposed gross negligence penalties for unreported income from a Swiss bank account and for failing to…
Continue reading “Swiss bank account trouble”…

Price adjustment clause

An accounting colleague has reported to me on a CRA audit involving a price adjustment clause. The CRA challenged the valuation used for a transfer of property. The taxpayer and the CRA eventually agreed on a valuation that was about…
Continue reading “Price adjustment clause”…

Recent Posts

Guest post on the DTC

The following article on the disability tax credit was written by Tanya O’Connell, a former law clerk at Loukidelis Professional Corporation. The Disability Tax Credit (DTC) The DTC is a personal tax credit available under section 118.3 of the Income…
Continue reading “Guest post on the DTC”…

Inter-company loans

Subsection 15(1) of the Income Tax Act could apply where Aco loans money to Bco and Bco has no means of repaying the money. On the other hand, subsection 246(1) will not apply where Bco and its shareholder have no…
Continue reading “Inter-company loans”…

Change in use and flipping

The CRA has confirmed that a deemed disposition under subsection 45(1) of the Income Tax Act resulting from a change in use is not a disposition for the purposes of the flipping rules in subsections 12(12) and 12(13). See 2024-1027831C6.
Continue reading “Change in use and flipping”…

Swiss bank account trouble

In Azmayesh-Fard v R, 2025 TCC 20, the Court considered whether the CRA had properly reassessed a taxpayer beyond the normal reassessment period and imposed gross negligence penalties for unreported income from a Swiss bank account and for failing to…
Continue reading “Swiss bank account trouble”…

Price adjustment clause

An accounting colleague has reported to me on a CRA audit involving a price adjustment clause. The CRA challenged the valuation used for a transfer of property. The taxpayer and the CRA eventually agreed on a valuation that was about…
Continue reading “Price adjustment clause”…

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Archives

Categories

Recent Posts

Guest post on the DTC

The following article on the disability tax credit was written by Tanya O’Connell, a former law clerk at Loukidelis Professional Corporation. The Disability Tax Credit (DTC) The DTC is a personal tax credit available under section 118.3 of the Income…
Continue reading “Guest post on the DTC”…

Inter-company loans

Subsection 15(1) of the Income Tax Act could apply where Aco loans money to Bco and Bco has no means of repaying the money. On the other hand, subsection 246(1) will not apply where Bco and its shareholder have no…
Continue reading “Inter-company loans”…

Change in use and flipping

The CRA has confirmed that a deemed disposition under subsection 45(1) of the Income Tax Act resulting from a change in use is not a disposition for the purposes of the flipping rules in subsections 12(12) and 12(13). See 2024-1027831C6.
Continue reading “Change in use and flipping”…

Swiss bank account trouble

In Azmayesh-Fard v R, 2025 TCC 20, the Court considered whether the CRA had properly reassessed a taxpayer beyond the normal reassessment period and imposed gross negligence penalties for unreported income from a Swiss bank account and for failing to…
Continue reading “Swiss bank account trouble”…

Price adjustment clause

An accounting colleague has reported to me on a CRA audit involving a price adjustment clause. The CRA challenged the valuation used for a transfer of property. The taxpayer and the CRA eventually agreed on a valuation that was about…
Continue reading “Price adjustment clause”…

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