I often send links to clients and colleagues by email, but sometimes the links are extremely long and complicated so that they are broken and unusable when they arrive at their destination. That’s where tinyurl.com comes in handy. “http://www.lawtimesnews.com/Headline-News/Record-$169-million-award-will-raise-the-bar” becomes…
Reorgs
Despite the many technical pitfalls in the reorganization provisions of the Income Tax Act, cases involving those provisions do not often come before the Tax Court. Husky Oil Limited v. The Queen, 2009 TCC 118, is one such case that…
Capital dividends and 160
The Tax Court, in Neumann v. The Queen, 2009 TCC 81, has decided that a capital dividend is a transfer of property for the purposes of section 160, just like an ordinary dividend.
Capital Dividends Again
The following article appeared in the latest edition of the Hamilton Law Association Law Journal.
Corrupt
No doubt some taxpayers believe that the CRA is corrupt, but the truth is that most CRA personnel are dedicated and professional civil servants. On the other hand, it’s not necessarily lily-white either.
Nerd update
In the interests of doing my part to be part of Web 2.0, I’ve deleted my page on this blog devoted to links of interest to tax practitioners, and I’ve created a page of links at delicious.com instead. Those of…
Tax Nerd
Paragraph 149.1(4)(c) in my version of the Practitioner’s Income Tax Act (35th edition) is missing an “or” at the end of it. I emailed David Sherman, the PITA editor, about this, and he confirmed that the “or” was missing in…
Election for Restrictive Covenants
Bryan Walters at Wade Group was kind enough to forward to me a link to the five-page “election letter” that the CRA wants taxpayers to use who are making elections under subsection 56.4(3) of the Income Tax Act.
Local flavour
Here’s a case with some local flavour, of a sort: Dundurn Street Loffts Inc. v. The Queen, 2009 TCC 122.
Class action
Sorbara v. Canada (Attorney General), 2008 CanLII 61246 (ON S.C.) is an interesting case about class action proceedings and Tax Court appeals. The moral of the story: the Tax Court has exclusive jurisdiction over tax matters even though it (probably)…