ABILs
Given the economic climate, it’s not surprising that we are receiving a lot questions about allowable business investment losses (ABILs). Nor is it surprising that many taxpayers find it difficult to claim ABILs, given the many pitfalls.
New blogger
Double Taxation in US Health Care Reform
A recent Tax Court of Canada decision raises concerns of double taxation in proposed US health care reforms. The case is Niemeijer v. The Queen, 2009 TCC 624.
Trust accounts
In Canada Trustco Mortgage Company v. The Queen, 2008 TCC 482, aff’d 2009 FCA 267, the Tax Court held that a financial institution must comply with a requirement to pay even where the the funds sought to be seized from the institution were held in a lawyer’s trust account.
Audit headlines
Retail Loses Again
Taxpayers who participated in ‘retail’ donation tax shelters continue to fare poorly in the Tax Court. See Maréchaux v. The Queen, 2009 TCC 587.
Triangles
Don’t forget the triangular amalgamation. While these types of amalgamations are more typical in the public company context, they can be a useful tool for private company deals too.