The Ontario government has announced that it “is undertaking a project to review and reform the Ontario Corporations Act (CA)”. The government is inviting “comments and suggestions from stakeholders and from the public regarding the reform of this important legislation.”
Charity Law Symposium
I spoke about split receipts at the Canadian Bar Association’s National Charity Law Symposium in Toronto today. You can download my presentation here. You can also download a “decision tree” that highlights the issues to be considered in issuing split…
Redeemer Goes to Ottawa
The Supreme Court of Canada today granted Redeemer Foundation’s “application for leave to appeal with costs to the applicant in any event of the cause.” The plot thickens. For my comments on this case, search for “Redeemer” on this…
Debate on Bill C-33
Voluntary disclosure update
The CRA has posted an update on its no-names voluntary disclosure program.
Trouble for a charity
I reported on a tax case involving All Saints Greek Orthodox Church here. Now the Toronto Star is reporting that the church issued receipts with a total value of about $273 million as part of the program under audit in…
Get help!
Beth DeMerchant, formerly of Torys LLP, testified earlier this week about her role in not making public non-compete fees paid to Lord Black (among others) in 2000. She is quoted in this morning’s National Post saying violated the most…
Testamentary Trusts
The following article on testamentary trusts appeared in the latest edition of the Hamilton Law Association Law Journal.
Schemes
As readers of this newsletter well know, the clear message from the courts lately has been “Woe unto you taxpayers who participate in retail tax shelters or other tax-driven schemes!” The Federal Court of Appeal has reiterated that message in Nunn v. The Queen, 2006 FCA 403 (decision not yet available online).
ABILs
To claim an allowable business investment loss (an ABIL) in respect of an amount loaned to a corporation, a taxpayer must establish (among other things) that the amount has become a bad debt. Kyriazakos v. The Queen, 2007 TCC 66,…