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LPC Notes

Wilful Blindness

Posted on: April 14, 2021 Last updated on: April 16, 2021 Written by: John Loukidelis
For the purposes of GST gross negligence penalties, a taxpayer will be treated as having made a misrepresentation ‘knowingly’ if the taxpayer was wilfully blind: if the taxpayer had reason to know that he or she should be making inquiries…
Continue reading “Wilful Blindness”…

Corporate Appellants Need Lawyers

Posted on: April 13, 2021 Last updated on: April 16, 2021 Written by: John Loukidelis
“In Canada v BCS Group Business Services Inc. (2020 FCA 205), the FCA held that a lawyer must represent a corporate appellant in a TCC general procedure appeal.” John Loukidelis “Corporate Appellants Need Lawyers” Tax for the Owner-Manager 21:2 (April…
Continue reading “Corporate Appellants Need Lawyers”…

Inventory adjustment disallowed

Posted on: April 12, 2021 Last updated on: April 16, 2021 Written by: John Loukidelis
In Yorkwest Plumbing Supply Inc. v R, 2020 TCC 122, the Court considered an adjustment of $1.2 million that the taxpayer had made to its 2012 net income in respect of inventory that had been purchased and sold before the…
Continue reading “Inventory adjustment disallowed”…

TIP case

Posted on: April 12, 2021 Last updated on: April 16, 2021 Written by: John Loukidelis
Motter c Agence du revenue du Québec, 2021 QCCA 72, aff’g 2018 QCCQ 3483, found that tenant inducement payments “are not an expense category for the purpose of calculating income from a business or property, nor are they a subcategory…
Continue reading “TIP case”…

Series of transactions

Posted on: April 10, 2021 Last updated on: April 16, 2021 Written by: John Loukidelis
In Agence du revenu du Québec c Custeau, 2020 QCCA 1496, the Court considered whether PUC shift and a subsequent reduction of that PUC were part of the same series of transactions such that the Quebec GAAR would apply to…
Continue reading “Series of transactions”…

Post-mortem charitable giving using corporate-owned insurance

Posted on: April 8, 2021 Last updated on: April 16, 2021 Written by: John Loukidelis
Mr X dies owning the shares of Opco. Opco receives a large payout under a life policy it held on X’s life. X’s Will provides for a gift to a charity. How does the estate make the gift using the…
Continue reading “Post-mortem charitable giving using corporate-owned insurance”…

Trusts and Dividends, Again

Posted on: April 7, 2021 Last updated on: April 7, 2021 Written by: John Loukidelis
The CRA believes that a dividend paid to a trust that is then paid to an individual during a year is not allocated until the end of the year (ie December 31 for inter vivos trusts) (CRA technical interpretation 2016-0647621E5,…
Continue reading “Trusts and Dividends, Again”…

QSBCS gains flow through tiered trusts

Posted on: March 23, 2021 Last updated on: March 23, 2021 Written by: John Loukidelis
taxinterpretations.com notes that the CRA, in technical interpretation 2019-0818301I7F (August 13, 2020), has now accepted that a gain realized on the sale of QSBCSs for which an individual could claim the capital gain exemption can be flowed through two levels…
Continue reading “QSBCS gains flow through tiered trusts”…

Climate change and SRED

Posted on: March 23, 2021 Last updated on: March 23, 2021 Written by: John Loukidelis
Tax and climate change intersected in 6398316 Canada Inc. v R, 2021 TCC 17. The Tax Court denied scientific research and experimental development (SRED) tax credits to a corporation that built a passive house. The Court found that the corporation…
Continue reading “Climate change and SRED”…

VDs and enforcement against a related person

Posted on: March 23, 2021 Last updated on: March 23, 2021 Written by: John Loukidelis
The taxpayer, in a previous application (2019 FC 51), succeeded in having the Court order the CRA to reconsider its decision because it did not adequately address how the demand for returns from the individual would have uncovered the corporation’s…
Continue reading “VDs and enforcement against a related person”…
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Recent notes

Wilful Blindness

For the purposes of GST gross negligence penalties, a taxpayer will be treated as having made a misrepresentation ‘knowingly’ if the taxpayer was wilfully blind: if the taxpayer had reason to know that he or she should be making inquiries…
Continue reading “Wilful Blindness”…

Corporate Appellants Need Lawyers

“In Canada v BCS Group Business Services Inc. (2020 FCA 205), the FCA held that a lawyer must represent a corporate appellant in a TCC general procedure appeal.” John Loukidelis “Corporate Appellants Need Lawyers” Tax for the Owner-Manager 21:2 (April…
Continue reading “Corporate Appellants Need Lawyers”…

Inventory adjustment disallowed

In Yorkwest Plumbing Supply Inc. v R, 2020 TCC 122, the Court considered an adjustment of $1.2 million that the taxpayer had made to its 2012 net income in respect of inventory that had been purchased and sold before the…
Continue reading “Inventory adjustment disallowed”…

TIP case

Motter c Agence du revenue du Québec, 2021 QCCA 72, aff’g 2018 QCCQ 3483, found that tenant inducement payments “are not an expense category for the purpose of calculating income from a business or property, nor are they a subcategory…
Continue reading “TIP case”…

Series of transactions

In Agence du revenu du Québec c Custeau, 2020 QCCA 1496, the Court considered whether PUC shift and a subsequent reduction of that PUC were part of the same series of transactions such that the Quebec GAAR would apply to…
Continue reading “Series of transactions”…

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