Merry Christmas everyone, from your friends at the Department of Finance: Government of Canada Announces Technical Amendments to Clarify the Specified Investment Flow-Through Entity Tax Rules.
Interest relief
The late 1980’s and early 1990’s were riotous times for tax shelters and their promoters. Unfortunately, many of them tended to leave taxpayers with severe hangovers in the form of large tax bills complete with assessments for interest amounts that tripled or quadrupled the amount of tax payable. What to do about that interest?
Bill C-28
Bill C-28—”an Act to implement certain provisions of the budget tabled in Parliament on March 19, 2007 and to implement certain provisions of the economic statement tabled in Parliament on October 30, 2007″—received Royal Assent on Friday. The bill became…
Third parties
One of my very first posts on this blog dealt with demands for information about third parties. The saga continues in Canada (National Revenue) v. The Greater Montréal Real Estate Board, 2006 FC 1069, in which the Court vacated its own ex parte order requiring the Board to turn over the information requested by the CRA. The Court founds as follows:
10 Years
In a post I wrote some time ago, I argued that the 10-year limitation rule for fairness (taxpayer relief) applications is ambiguous. I also noted that the CRA believes the rule is clear, and apparently it maintains that position still,…
CRA Report
The CRA has made its annual report to Parliament, and parts of it make for interesting reading. Essentially the report amounts to the CRA’s report card on itself. The report discusses outstanding tax debts among other things. The report notes…
Income-splitting gone wrong
In Demers c. La Reine, 2006 CCI 504, the taxpayer tried to split income with his minor daughters. The Court ruled against the taxpayer, in part because it considered artificial the payment of thousands of dollars of dividends on shares that were issued for only $1.
C-10
Bill C-10 has received second reading in the Senate and has been referred to committee.
Non-competes
Yesterday, I spoke about the new rules for non-competes at an HLA-sponsored seminar. Frankly, my speaking notes aren’t as clear as I would like them to be, even allowing for the fact that the new rules are (needlessly) complex. I…
News releases
The CRA issued a couple of news releases yesterday. One of them warned about RSP “scams”, and the other announced that the CRA had issued a notice of suspension to ‘International Charity Association Network.’ The Department of Finance announced today…