I’ve written before concerning my doubts about the advisability of issuing shares that are redeemable for a nominal amount but that are entitled to unlimited dividends. Robin MacKnight does not share these concerns: he appears to have no qualms about…
Otteson and the capital gain exemption
The provisions of the Income Tax Act governing when a taxpayer can claim the capital gain exemption in respect of farm property are complex. Otteson v R, 2014 TCC 250, is an interesting case that navigates the provisions in the context of a rather complex set of facts.
Being Digital
From “Paperless Tip” at Lawyerist.com: Never ever ever send a Word file as “correspondence.” A Word file — or a WordPerfect, OpenOffice.org, or Pages file — is not a document. PDFs are documents. Word files are drafts. And sending a…
Paper-less
Neal Armstrong at taxinterpretations.com reported yesterday on CRA TI 2014-0526121E5, which confirmed that electronic copies of original records should suffice for the purposes of complying with the provisions of the Income Tax Act relating to business records. Keeping originals might…
The ONCA: Not Until 2016
It appears the “new” Not-for-Profit Corporations Act, 2010 will not come into force before 2016 according to a post from early June on the Ministry of Government and Consumer Services website.
The T1135, Again
The saga continues: Form T1135 – Reporting for 2014 and later tax years.
Filing nil returns to avoid penalties
Can taxpayers, by filing nil returns, avoid late-filing penalties and begin the beginning of the normal reassessment period? The CRA says ‘no’ in technical 2014-0519701I7. The CRA says that, even if it issues a notice of assessment in response to…
Informant Program
According to the CBC, the CRA’s offshore tax informant program has generated a “flood” of calls from would-be informants. Here is yet another reasons to do a voluntary disclosure sooner than later.
CRA Price Adjustment Clauses Update
The following article appeared in the June, 2014, issue of the Hamilton Law Association HLA Journal.
Lawyers who must draft price adjustment clauses (“PACs”) will want to read Income Tax Folio S4-F3-C1 (the ‘Folio’), which the CRA has issued and updated recently to replace the venerable Interpretation Bulletin IT-169. The following article discusses some of the Folio’s highlights.
Local interest
Here’s a case of interest to tax advisers and residents of the Hamilton area. In Henco Industries Limited v R, 2014 TCC 192, the Court dealt with the tax treatment of certain payments received from the Government of Ontario by…