• Skip to main navigation
  • Skip to main content
  • Skip to footer
Loukidelis PC

Loukidelis PC

Effective. Accessible. Responsive

  • Services
  • Team
  • LPC Notes
  • Articles
  • Privacy Policy
  • Contact Us
  • Disclaimer
  • Skip to menu toggle button

Author: John Loukidelis (page 17)

Retiring allowance and RRSP room

Posted on: March 11, 2022 Last updated on: March 11, 2022 Written by: John Loukidelis
In Wyrstiuk v. The Queen, 2022 TCC 10 (informal procedure), the Court held that a retiring allowance is not ‘earned income’ for the purposes of computing RRSP contribution room.
Continue reading “Retiring allowance and RRSP room”…

CRA interviews

Posted on: February 16, 2022 Last updated on: February 16, 2022 Written by: John Loukidelis
The 2021 Federal budget proposed to amend the Income Tax Act (Canada) to permit the CRA to demand interviews with owner-managers and their employees. The authors note the potential for mischief or worse where an auditor interviews an unprepared owner-manager…
Continue reading “CRA interviews”…

Shareholder loan repayment after death

Posted on: February 15, 2022 Last updated on: February 15, 2022 Written by: John Loukidelis
In technical interpretation 2012-0442911C6 (June 2012), the CRA confirmed that subsection 15(2.6) will apply to prevent the amount of a shareholder loan from being included in the shareholder’s income if his estate repays the loan before the end of the…
Continue reading “Shareholder loan repayment after death”…

Reassessment beyond the normal reassessment period

Posted on: February 15, 2022 Last updated on: February 15, 2022 Written by: John Loukidelis
This article discusses Hansen v R, 2020 TCC 102. In our view, the Hansen decision is consistent with the four-part test established in Aridi v R, 2013 TCC 74. Mr. Hansen was aware that there was a PRE and that…
Continue reading “Reassessment beyond the normal reassessment period”…

Gifts by Will

Posted on: February 14, 2022 Last updated on: February 14, 2022 Written by: John Loukidelis
S 161(7) provides that interest on taxes payable for a year should be computed without reference to any reduction of tax payable resulting from the carryback of donation credits where a gift is made in a subsequent taxation year. The…
Continue reading “Gifts by Will”…

82(3) elections and TOSI

Posted on: February 14, 2022 Last updated on: February 14, 2022 Written by: John Loukidelis
This articles review the interaction of the subsection 82(3) election and the TOSI rules. “n the CRA’s view, the correct method of applying the two provisions is to allocate receipt of the dividends in accordance with subsection 82(3) and then…
Continue reading “82(3) elections and TOSI”…

CRA problems with 55(3)(a) butterflies

Posted on: February 11, 2022 Last updated on: February 11, 2022 Written by: John Loukidelis
The CRA might apply the GAAR to a 55(3)(a) butterfly if A + B > C where A is the ACB of the remaining shares in the capital of DC after the butterfly B is the ACB of the DC…
Continue reading “CRA problems with 55(3)(a) butterflies”…

Part IV tax and amalgamations

Posted on: February 11, 2022 Last updated on: February 11, 2022 Written by: John Loukidelis
Benco is a beneficiary of a trust that owns all of the issued shares of each of Opco1 and Opco2. On November 30, Opco1 pays a dividend to the trust, which allocates it to Benco. Opco1 does not receive a…
Continue reading “Part IV tax and amalgamations”…

Good news on trust reporting

Posted on: February 2, 2022 Last updated on: February 2, 2022 Written by: John Loukidelis
Neil Armstrong notes that the CRA will not require trust to provide additional beneficial ownership information for 2021 because the relevant legislation has not been enacted yet.
Continue reading “Good news on trust reporting”…

Betrayed by fonts

Posted on: February 2, 2022 Last updated on: February 2, 2022 Written by: John Loukidelis
This story warmed my font-nerd heart. A bankruptcy trustee hired an expert in typography and design who testified that a document supposedly created in 1995 used fonts that weren’t available to the public until 2007. *Sad trombone sound*.
Continue reading “Betrayed by fonts”…
« Previous page 1 … 15 16 17 18 19 … 107 Next page »

Archives

Categories

Recent notes

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”…

Archives

Categories

Meta

  • Log in
  • Entries feed
  • Comments feed
  • WordPress.org

About this site

Click here for an important disclaimer about this site.

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”…

© Loukidelis Professional Corporation