• 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 53)

Tax preparation and police checks

Posted on: December 20, 2014 Last updated on: December 20, 2014 Written by: John Loukidelis
The CRA runs a volunteer tax preparer program, which is a Smart Idea. Beginning in 2016, the CRA will require all volunteer preparers to get police checks, which is a Dumb Idea.
Continue reading “Tax preparation and police checks”…

Estate freezes and accounting

Posted on: December 10, 2014 Last updated on: December 11, 2014 Written by: John Loukidelis
KPMG reports that If you’re a business owner and you have carried out an estate freeze to fix the value of your shares in the business so that future growth accrues to the benefit of other family members, you may…
Continue reading “Estate freezes and accounting”…

Consent steeplechase

Posted on: December 9, 2014 Last updated on: December 20, 2014 Written by: John Loukidelis
Craig Burley reports on the latest from the CRA about authorizations. Apparently Tax Centres are no longer processing faxed authorization forms. Update December 19, 2014. I spoke to an Appeals officer today who said that I couldn’t fax an authorization…
Continue reading “Consent steeplechase”…

97(2) Abuse

Posted on: December 4, 2014 Last updated on: December 4, 2014 Written by: John Loukidelis
The CRA says that forming a partnership consisting only of Canadian partners to take advantage of the 97(2) rollover and then immediately afterward adding a non-resident partner is abusive. It would attempt to apply the GAAR. (CTF Roundtable Q6).
Continue reading “97(2) Abuse”…

Restrictive covenant relief

Posted on: December 4, 2014 Last updated on: December 4, 2014 Written by: John Loukidelis
Earlier this year, the CRA said that nominal consideration for a non-compete would be proceeds of disposition so that 56.4(7) would not apply to the covenant. Apparently, the CRA reversed this position at the CTF Roundtable yesterday: $1 (but no…
Continue reading “Restrictive covenant relief”…

New folio on amalgamations

Posted on: December 2, 2014 Last updated on: December 2, 2014 Written by: John Loukidelis
The CRA has published a new folio on amalgamations here.
Continue reading “New folio on amalgamations”…

Tax simplification

Posted on: December 2, 2014 Last updated on: December 2, 2014 Written by: John Loukidelis
John Manley, speaking at the Canadian Tax Foundation‘s national conference yesterday, made the case for tax simplification. To which I say “Hah!” I’m just waiting for the “My grandfather was a Greek immigrant who ran a restaurant in North Bay…
Continue reading “Tax simplification”…

HST and damages

Posted on: November 22, 2014 Last updated on: November 22, 2014 Written by: John Loukidelis
Greg Sawatsky has written a helpful summary of the HST rules applying to certain payments of damages.
Continue reading “HST and damages”…

Objections Can Result in a Bigger Tax Bill

Posted on: November 20, 2014 Last updated on: November 20, 2014 Written by: John Loukidelis
The CRA takes the position that an Appeals officer can issue a reassessment that increases a tax liability if new information supporting the increase comes to light as part of the objection process. Amanda Doucette, “Filing a Notice of Objection…
Continue reading “Objections Can Result in a Bigger Tax Bill”…

Loss Carrybacks and Reassessments

Posted on: November 20, 2014 Last updated on: November 20, 2014 Written by: John Loukidelis
Alex Klyguine reminds us that, if the CRA reassesses a year and the taxpayer wishes to dispute the reassessment, the taxpayer must be cautious about applying losses of other years to reduce the taxable income of the reassessed year. If…
Continue reading “Loss Carrybacks and Reassessments”…
« Previous page 1 … 51 52 53 54 55 … 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