• 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 27)

OFFICE CLOSED

Posted on: March 16, 2020 Last updated on: July 3, 2020 Written by: John Loukidelis
In view of the fast-developing COVID-19 pandemic, our office will be closed to the public until further notice. We remain available to assist clients via phone, email and video conference.
Continue reading “OFFICE CLOSED”…

Family law tax pitfalls

Posted on: March 6, 2020 Last updated on: March 6, 2020 Written by: John Loukidelis

Alison Boyce tweeted today about an interesting article published recently in The National magazine. The article describes CBA efforts to convince the Department of Finance that it needs to re-visit the tax rules affecting shared parenting.

Continue reading “Family law tax pitfalls”…

TOSI and foreign affiliates

Posted on: March 2, 2020 Last updated on: March 2, 2020 Written by: John Loukidelis
The TOSI rules don’t just apply to dividends from Canadian private corporations. The rules can apply to dividends from foreign private corporations as well, and the tax results are potentially horrendous. Stan Shadrin, Manu Kakkar and Alex Ghani, “FAPI and…
Continue reading “TOSI and foreign affiliates”…

TOSI and business reorganizations

Posted on: March 2, 2020 Last updated on: March 2, 2020 Written by: John Loukidelis
In a technical interpretation (TI 2019-0814181E5, August 19, 2019), the CRA confirmed that the five-year test to qualify for the “excluded business” exception under the TOSI (tax on split income) rules should take into account all taxation years in which…
Continue reading “TOSI and business reorganizations”…

Estates and foreign affiliate dumping

Posted on: March 2, 2020 Last updated on: March 2, 2020 Written by: John Loukidelis
The draft foreign affiliate dumping rules can create a deemed dividend to a non-resident discretionary beneficiary of the estate of an owner of a private Canco that holds shares in a foreign affiliate. Henry Shaw, “Foreign Affiliate Dumping and Estates…
Continue reading “Estates and foreign affiliate dumping”…

Central mind and management

Posted on: March 2, 2020 Last updated on: March 2, 2020 Written by: John Loukidelis
In Landbouwbedrijf Backx BV v Canada, 2019 FCA 310, the Court agreed that a Dutch company was resident in Canada because the central mind and management of the company was in Canada. The Court found the following facts to be…
Continue reading “Central mind and management”…

SCC on judicial review

Posted on: March 2, 2020 Last updated on: March 2, 2020 Written by: John Loukidelis
Gergely Hegedus, “SCC on Standards of Judicial Review” (February 2020) 10:1 Canadian Tax Focus, draws the following lessons from Canada (Minister of Citizenship and Immigration) v Vavilov, 2019 SCC 65, Bell Canada v Canada (Attorney General), 2019 SCC 66, and…
Continue reading “SCC on judicial review”…

Commission employees

Posted on: March 2, 2020 Last updated on: March 2, 2020 Written by: John Loukidelis
The trend in Tax Court jurisprudence is to require specificity in contracts to permit a commissioned employee to deduct an expense. The contract must contemplate the particular expense in question before it will be deductible under paragraph 8(1)(f) of the…
Continue reading “Commission employees”…

ABIL denied

Posted on: November 27, 2019 Last updated on: November 27, 2019 Written by: John Loukidelis
In Moose Factory Restaurant Properties Ltd. v R, 2019 TCC 156, the taxpayer claimed an ABIL in respect of a debt of a third party that the taxpayer had guaranteed. The third party went bankrupt leaving the taxpayer exposed under…
Continue reading “ABIL denied”…

The Tax Court and the implied undertaking rule

Posted on: November 26, 2019 Last updated on: November 26, 2019 Written by: John Loukidelis
In Silver Wheaton Corp. v R, 2019 TCC 170, the Court held that the implied undertaking rule prevented third parties from obtaining the production of documents and information produced by the taxpayer in a Tax Court appeal. Bhuvana Sankaranarayanan, “Third…
Continue reading “The Tax Court and the implied undertaking rule”…
« Previous page 1 … 25 26 27 28 29 … 107 Next page »

Archives

Categories

Recent notes

Canada Child Benefit and Shared Custody

In Wong v R, 2025 TCC 24 (informal procedure), Mr Justice Bocock provided a helpful road map of the surprisingly complicated rules relating to shared custody and entitlement to the Canada Child Benefit.
Continue reading “Canada Child Benefit and Shared Custody”…

Misdirected assessment

Poor Mr Lam trusted his tenant to forward important mail while Mr Lam was out of the country, but the tenant left a 2016 HST assessment in a pile of junk mail. Mr Lam didn’t become aware of the assessment…
Continue reading “Misdirected assessment”…

50-50 shareholders and s 160; directors and independent contractors

McCague v R, 2025 TCC 59, is another section 160 case where 50/50 shareholders caused their corporation to pay them dividends at a time when it owed taxes. The Court held that section 160 applied and summarized the law in…
Continue reading “50-50 shareholders and s 160; directors and independent contractors”…

Preliminary vs preparatory expenses

In Lienaux v R, 2025 TCC 67 (informal procedure), the Court referred to Vesuna v R, 2022 FCA 58, and Gartry v R, 1994 CanLII 19352 (TCC), in denying expenses incurred where the taxpayer had not actually started to carry…
Continue reading “Preliminary vs preparatory expenses”…

Negligence for not reviewing return

In 994552 N.W.T. Ltd. v R, 2025 TCC 55, Mr Justice Bocock considered whether the taxpayer corporation was liable to be reassessed beyond the normal reassessment period for two taxation years and for gross negligence penalties for overclaimed capital cost…
Continue reading “Negligence for not reviewing return”…

Recent Posts

Canada Child Benefit and Shared Custody

In Wong v R, 2025 TCC 24 (informal procedure), Mr Justice Bocock provided a helpful road map of the surprisingly complicated rules relating to shared custody and entitlement to the Canada Child Benefit.
Continue reading “Canada Child Benefit and Shared Custody”…

Misdirected assessment

Poor Mr Lam trusted his tenant to forward important mail while Mr Lam was out of the country, but the tenant left a 2016 HST assessment in a pile of junk mail. Mr Lam didn’t become aware of the assessment…
Continue reading “Misdirected assessment”…

50-50 shareholders and s 160; directors and independent contractors

McCague v R, 2025 TCC 59, is another section 160 case where 50/50 shareholders caused their corporation to pay them dividends at a time when it owed taxes. The Court held that section 160 applied and summarized the law in…
Continue reading “50-50 shareholders and s 160; directors and independent contractors”…

Preliminary vs preparatory expenses

In Lienaux v R, 2025 TCC 67 (informal procedure), the Court referred to Vesuna v R, 2022 FCA 58, and Gartry v R, 1994 CanLII 19352 (TCC), in denying expenses incurred where the taxpayer had not actually started to carry…
Continue reading “Preliminary vs preparatory expenses”…

Negligence for not reviewing return

In 994552 N.W.T. Ltd. v R, 2025 TCC 55, Mr Justice Bocock considered whether the taxpayer corporation was liable to be reassessed beyond the normal reassessment period for two taxation years and for gross negligence penalties for overclaimed capital cost…
Continue reading “Negligence for not reviewing return”…

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

Canada Child Benefit and Shared Custody

In Wong v R, 2025 TCC 24 (informal procedure), Mr Justice Bocock provided a helpful road map of the surprisingly complicated rules relating to shared custody and entitlement to the Canada Child Benefit.
Continue reading “Canada Child Benefit and Shared Custody”…

Misdirected assessment

Poor Mr Lam trusted his tenant to forward important mail while Mr Lam was out of the country, but the tenant left a 2016 HST assessment in a pile of junk mail. Mr Lam didn’t become aware of the assessment…
Continue reading “Misdirected assessment”…

50-50 shareholders and s 160; directors and independent contractors

McCague v R, 2025 TCC 59, is another section 160 case where 50/50 shareholders caused their corporation to pay them dividends at a time when it owed taxes. The Court held that section 160 applied and summarized the law in…
Continue reading “50-50 shareholders and s 160; directors and independent contractors”…

Preliminary vs preparatory expenses

In Lienaux v R, 2025 TCC 67 (informal procedure), the Court referred to Vesuna v R, 2022 FCA 58, and Gartry v R, 1994 CanLII 19352 (TCC), in denying expenses incurred where the taxpayer had not actually started to carry…
Continue reading “Preliminary vs preparatory expenses”…

Negligence for not reviewing return

In 994552 N.W.T. Ltd. v R, 2025 TCC 55, Mr Justice Bocock considered whether the taxpayer corporation was liable to be reassessed beyond the normal reassessment period for two taxation years and for gross negligence penalties for overclaimed capital cost…
Continue reading “Negligence for not reviewing return”…

© Loukidelis Professional Corporation