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LPC Notes

Foreignco owning a vacation property

Posted on: December 2, 2023 Last updated on: November 27, 2023 Written by: John Loukidelis
The CRA confirmed that a non-resident corporation that owns a Canadian vacation property confers a benefit on its non-resident shareholders where the shareholders or non-arm’s length persons use the property. The benefit, as a deemed dividend (214(3)(a)), is subject to…
Continue reading “Foreignco owning a vacation property”…

Deduction for TOSI under 20(1)(ww)

Posted on: December 1, 2023 Last updated on: November 27, 2023 Written by: John Loukidelis
A taxpayer can deduct an amount under paragraph 20(1)(ww) even if the taxpayer must include a taxable capital gain in income that is subject to TOSI but he or she can offset the gain with an allowable capital loss. STEP…
Continue reading “Deduction for TOSI under 20(1)(ww)”…

Trusts and control

Posted on: November 29, 2023 Last updated on: November 27, 2023 Written by: John Loukidelis
The CRA accepts that, if A and B are the trustees of a trust that controls Corp1, and A and B also constitute a group that controls Corp2, then Corp1 and Corp2 are related to each other under subparagraph 251(2)(c)(i).…
Continue reading “Trusts and control”…

Preparer penalties

Posted on: November 28, 2023 Last updated on: November 28, 2023 Written by: John Loukidelis
I have become aware of a case where the CRA has imposed preparer penalties on an accountant who filed tax returns for corporations and their shareholders where the shareholders did not report income in respect of shareholder loan debit balances…
Continue reading “Preparer penalties”…

Post Number 1,000

Posted on: November 27, 2023 Last updated on: November 27, 2023 Written by: John Loukidelis
This post is number 1,000 in this, my blog about Canadian income tax law. I have been writing here more or less regularly, since August, 2005. I started writing the blog as a way of informing clients about recent developments…
Continue reading “Post Number 1,000”…

Reporting the ID of disaster clause beneficiaries

Posted on: November 23, 2023 Last updated on: November 15, 2023 Written by: John Loukidelis
At the STEP Canada 2023 Round Table, in answer to question 4, the CRA stated that a contingent beneficiary is a beneficiary for the purposes of subsection 204.2(2) of the Income Tax Regulations, which now requires trusts to provide identification…
Continue reading “Reporting the ID of disaster clause beneficiaries”…

Property of a trust that prevents the prevention of filing

Posted on: November 20, 2023 Last updated on: November 15, 2023 Written by: John Loukidelis
At the STEP Canada 2023 Round Table, in answer to question 3, the CRA stated that a trust settled with a gold or silver bar, or a collectible coin, cannot satisfy the exception in paragraph 150(1.2)(b) of the Income Tax…
Continue reading “Property of a trust that prevents the prevention of filing”…

Forgotten capital losses

Posted on: November 15, 2023 Last updated on: November 15, 2023 Written by: John Loukidelis
At the STEP Canada 2023 Round Table, in question 2, the CRA addressed a hypothetical question about the executors of an estate finding evidence of a capital loss realized years before that was not claimed. The CRA agreed that the…
Continue reading “Forgotten capital losses”…

Notifiable transactions list

Posted on: November 1, 2023 Last updated on: November 1, 2023 Written by: John Loukidelis
The CRA has posted the list of notifiable transactions that have been designated by the Minister of National Revenue effective today. In the email I received notifying me of the notifiable transactions list, the CRA wrote “The list of transactions…
Continue reading “Notifiable transactions list”…

Dividends paid to beneficiaryco, again

Posted on: October 26, 2023 Last updated on: October 26, 2023 Written by: John Loukidelis
In Vefghi Holding Corp. v R, 2023 TCC 135, the court provided the following answers to a Rule 58 Question: Where a trust designates a portion of a taxable dividend (the “Amount”) received on a share of the capital stock…
Continue reading “Dividends paid to beneficiaryco, again”…
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Foreignco owning a vacation property

The CRA confirmed that a non-resident corporation that owns a Canadian vacation property confers a benefit on its non-resident shareholders where the shareholders or non-arm’s length persons use the property. The benefit, as a deemed dividend (214(3)(a)), is subject to…
Continue reading “Foreignco owning a vacation property”…

Deduction for TOSI under 20(1)(ww)

A taxpayer can deduct an amount under paragraph 20(1)(ww) even if the taxpayer must include a taxable capital gain in income that is subject to TOSI but he or she can offset the gain with an allowable capital loss. STEP…
Continue reading “Deduction for TOSI under 20(1)(ww)”…

Trusts and control

The CRA accepts that, if A and B are the trustees of a trust that controls Corp1, and A and B also constitute a group that controls Corp2, then Corp1 and Corp2 are related to each other under subparagraph 251(2)(c)(i).…
Continue reading “Trusts and control”…

Preparer penalties

I have become aware of a case where the CRA has imposed preparer penalties on an accountant who filed tax returns for corporations and their shareholders where the shareholders did not report income in respect of shareholder loan debit balances…
Continue reading “Preparer penalties”…

Post Number 1,000

This post is number 1,000 in this, my blog about Canadian income tax law. I have been writing here more or less regularly, since August, 2005. I started writing the blog as a way of informing clients about recent developments…
Continue reading “Post Number 1,000”…

Recent Posts

Foreignco owning a vacation property

The CRA confirmed that a non-resident corporation that owns a Canadian vacation property confers a benefit on its non-resident shareholders where the shareholders or non-arm’s length persons use the property. The benefit, as a deemed dividend (214(3)(a)), is subject to…
Continue reading “Foreignco owning a vacation property”…

Deduction for TOSI under 20(1)(ww)

A taxpayer can deduct an amount under paragraph 20(1)(ww) even if the taxpayer must include a taxable capital gain in income that is subject to TOSI but he or she can offset the gain with an allowable capital loss. STEP…
Continue reading “Deduction for TOSI under 20(1)(ww)”…

Trusts and control

The CRA accepts that, if A and B are the trustees of a trust that controls Corp1, and A and B also constitute a group that controls Corp2, then Corp1 and Corp2 are related to each other under subparagraph 251(2)(c)(i).…
Continue reading “Trusts and control”…

Preparer penalties

I have become aware of a case where the CRA has imposed preparer penalties on an accountant who filed tax returns for corporations and their shareholders where the shareholders did not report income in respect of shareholder loan debit balances…
Continue reading “Preparer penalties”…

Post Number 1,000

This post is number 1,000 in this, my blog about Canadian income tax law. I have been writing here more or less regularly, since August, 2005. I started writing the blog as a way of informing clients about recent developments…
Continue reading “Post Number 1,000”…

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Archives

Categories

Recent Posts

Foreignco owning a vacation property

The CRA confirmed that a non-resident corporation that owns a Canadian vacation property confers a benefit on its non-resident shareholders where the shareholders or non-arm’s length persons use the property. The benefit, as a deemed dividend (214(3)(a)), is subject to…
Continue reading “Foreignco owning a vacation property”…

Deduction for TOSI under 20(1)(ww)

A taxpayer can deduct an amount under paragraph 20(1)(ww) even if the taxpayer must include a taxable capital gain in income that is subject to TOSI but he or she can offset the gain with an allowable capital loss. STEP…
Continue reading “Deduction for TOSI under 20(1)(ww)”…

Trusts and control

The CRA accepts that, if A and B are the trustees of a trust that controls Corp1, and A and B also constitute a group that controls Corp2, then Corp1 and Corp2 are related to each other under subparagraph 251(2)(c)(i).…
Continue reading “Trusts and control”…

Preparer penalties

I have become aware of a case where the CRA has imposed preparer penalties on an accountant who filed tax returns for corporations and their shareholders where the shareholders did not report income in respect of shareholder loan debit balances…
Continue reading “Preparer penalties”…

Post Number 1,000

This post is number 1,000 in this, my blog about Canadian income tax law. I have been writing here more or less regularly, since August, 2005. I started writing the blog as a way of informing clients about recent developments…
Continue reading “Post Number 1,000”…

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