From Craig Burley’s Twitter feed today: CRA and Heartbleed: http://craigburley.com/?p=47. “Change your passwords” is the general advice. CRA website login services are shuttered for now.
Another tax fraud?
From the “Here We Go Again” file: according to an RCMP news release he RCMP’s Greater Toronto Area (GTA) Financial Crime team has arrested and charged six people after thousands of investors and the Government of Canada lost millions of…
Typography for Lawyers
I have an interest in typography based in a belief that, because our work product so often consists of the documents we produce (at least in the eyes of our clients), we lawyers should take extra care with the appearance…
Housing Loans
Owner-managers and their advisers need to be wary of housing loans made to a private corporation’s controlling shareholder. In Mast v R, 2013 TCC 309, the Tax Court concluded that the exception to subsection 15(2) of the Income Tax Act…
Minute books
Too often, corporate minute books are taken for granted by their officers, directors and shareholders. My post earlier today reminded me that the problem to which it alludes often stems from a minute book that hasn’t been maintained properly. As…
Paying dividends, again
Neal Armstrong makes note of a recent CRA technical (French only), which confirms that the CRA might not recognize an amount supposedly “paid” as a dividend if it is supported only by accounting journal entries. The well-established principle, per Hickman…
Some recent rectification cases
Thanks to Craig Burley for pointing me to a recent newsletter article on McLean v McLean, 2013 ONCA 788. In the same vein, see also Neal Armstrong’s comment on Re: Pallen Trust, 2014 BCSC 305.
Tax Interpretations
Neal Armstrong, Abraham Leitner and Scott Armstrong have created Tax Interpretations, which is a very useful technical resource for those of us who must struggle with tax issues daily. The site includes access to CRA severed letters and summaries, posted…
T1135 News
The CRA has updated its information on the new T1135 reporting regime. For those of you with clients who hold foreign property through a Canadian brokerage account, take note of the following: Form T1135 excludes certain property from the detailed…
Debt forgiveness anti-avoidance rule
I came across an interesting (older) technical interpretation a few days ago while looking at another matter. In TI 2009-0338911E5, the CRA commented on the rules in section 80 of the Income Tax Act applicable to a CCPC that was winding-up voluntarily where, as a result of the winding-up, debt owed in equal amounts to the 50/50 shareholders of the corporation would be forgiven.