The Tax Court, in Kubbernus v. The Queen, 2009 TCC 311, confirmed that a taxpayer cannot file an appeal to the Court for a reassessment issued at the taxpayer’s request pursuant to the taxpayer relief provisions.
Paying dividends with a note
In a post I wrote last year, I stated
According to the CRA, it is not necessary to use cash to pay the dividend. A corporation can pay a dividend using a note, but the payee must accept the note as absolute payment of the dividend.
Transfers of insurance
I’ve seen a number of transactions lately where the owner of a life insurance policy proposes to transfer it to a corporation controlled by the owner. The benefits of corporate-owned insurance are well-known, of course, but such a transfer could also permit the owner to withdraw significant amounts of money from the corporation tax free.
Related Business
A charity cannot carry on a business unless it is a “related business”, which is a business that is related to the objects of the charity and that employs only volunteers. After the decision in Alberta Institute on Mental Retardation…
Death Benefits or Not
When is a ‘death benefit’ not a ‘death benefit’? Apparently, when it is a benefit received under the Canada Pension Plan.
Contradiction
In January I reported that the Tax Court had held that the penalty provided by subsection 163(2.1) of the Income Tax Act did not apply if the corporation filing the return did not have taxable income (see Goar, Allison &…
Webcasts
The CRA has produced a number of webcasts aimed at charities, to help them with their compliance burdens.
It’s criminal
Ok, so you make some rather large ‘mistakes’ on your tax return, and you end up owing the government a lot of money. What’s the worst that could happen?
Revival, for the third time
I have posted here and here on the effect of the dissolution of a corporation and its subsequent revival on the liability of a director for source deductions and the like. The CRA has now weighed in with a technical…
Fundraising
The CRA has issued new guidelines on fundraising for charities.