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LPC Notes (page 3)

Purported shareholder loan repayments treated as income

Posted on: October 30, 2024 Last updated on: October 24, 2024 Written by: John Loukidelis
In Kumar v R, 2024 TCC 105 (informal procedure), the Court found that the CRA had properly reassessed the appellant to include in his income payments to him and his son made by a corporation to which the appellant had…
Continue reading “Purported shareholder loan repayments treated as income”…

Minister accepts VD but then reassesses other years anyway

Posted on: October 24, 2024 Last updated on: October 24, 2024 Written by: John Loukidelis
In Milgram Foundation v. Canada (Attorney General), 2024 FC 1405, the Federal Court quashed a decision to reassess a taxpayer for taxation years before years for which the taxpayer had made a voluntary disclosure. The CRA had accepted the disclosure…
Continue reading “Minister accepts VD but then reassesses other years anyway”…

TFSA trading business

Posted on: October 10, 2024 Last updated on: October 10, 2024 Written by: John Loukidelis
Canadian Western Trust Company v. Canada, 2024 FCA 108, affirmed 2023 TCC 17, which had confirmed assessments issued to a TFSA because, the CRA had alleged, it had engaged in a securities trading business.
Continue reading “TFSA trading business”…

Section 160 taxpayer win

Posted on: October 2, 2024 Last updated on: September 25, 2024 Written by: John Loukidelis
In Vasilkioti v R, 2024 TCC 101, the Court held that section 160 did not apply in respect of a transfer of real property from a husband to the appellant-wife because the CRA did not adequately prove the husband’s underlying…
Continue reading “Section 160 taxpayer win”…

2024 STEP Roundtable Part 2

Posted on: September 25, 2024 Last updated on: September 25, 2024 Written by: John Loukidelis
In response to question 10, the CRA referred to Maurice Kissel Family Trust v R (unreported 2019-4092(IT)G). The trust in question prohibited the distribution of amounts to a “designated beneficiary”, but the trust purported to allocate and deduct gains it…
Continue reading “2024 STEP Roundtable Part 2”…

Trust allocations

Posted on: September 19, 2024 Last updated on: September 14, 2024 Written by: John Loukidelis
Fiducie Historia c HMK, 2024 CCI 76 (French only), affirmed the validity of trust allocations made by trustees where, the CRA alleged, another agreement (entered into to preserve capital losses in a corporation controlled by the trust) seemed to give…
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2024 STEP Roundtable

Posted on: September 14, 2024 Last updated on: September 14, 2024 Written by: John Loukidelis
The following is based on the text published in Tax Topics 2713 (September 10, 2024). Question 1 – Spousal Trusts A spousal trust that receives a contribution of capital after the death of the spouse-beneficiary remains a spousal trust, but…
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Appeal quashed

Posted on: September 6, 2024 Last updated on: September 2, 2024 Written by: John Loukidelis
In Cole v R, 2024 TCC 64, The Appellant spent the better part of ten years trying to convince the Minister of National Revenue to remove over $240,000 added to her taxable income for the 2011 taxation year. Due…
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Demands for information from non-residents

Posted on: September 2, 2024 Last updated on: September 2, 2024 Written by: John Loukidelis
Canada (National Revenue) v. Schreiber, 2024 FC 729, the Federal Court held that, in general, the CRA is entitled to demand information from non-resident persons or entities.
Continue reading “Demands for information from non-residents”…

Dissolved trust year-end

Posted on: July 26, 2024 Last updated on: July 26, 2024 Written by: John Loukidelis
At the 2024 CALU conference round table (question 12, addressed in 2024-1005851C6), the CRA confirmed that a bare trust has a December 31 year-end and that a trust (other than a GRE) that dissolves during a calendar year still has…
Continue reading “Dissolved trust year-end”…
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Guest post on the DTC

The following article on the disability tax credit was written by Tanya O’Connell, a former law clerk at Loukidelis Professional Corporation. The Disability Tax Credit (DTC) The DTC is a personal tax credit available under section 118.3 of the Income…
Continue reading “Guest post on the DTC”…

Inter-company loans

Subsection 15(1) of the Income Tax Act could apply where Aco loans money to Bco and Bco has no means of repaying the money. On the other hand, subsection 246(1) will not apply where Bco and its shareholder have no…
Continue reading “Inter-company loans”…

Change in use and flipping

The CRA has confirmed that a deemed disposition under subsection 45(1) of the Income Tax Act resulting from a change in use is not a disposition for the purposes of the flipping rules in subsections 12(12) and 12(13). See 2024-1027831C6.
Continue reading “Change in use and flipping”…

Swiss bank account trouble

In Azmayesh-Fard v R, 2025 TCC 20, the Court considered whether the CRA had properly reassessed a taxpayer beyond the normal reassessment period and imposed gross negligence penalties for unreported income from a Swiss bank account and for failing to…
Continue reading “Swiss bank account trouble”…

Price adjustment clause

An accounting colleague has reported to me on a CRA audit involving a price adjustment clause. The CRA challenged the valuation used for a transfer of property. The taxpayer and the CRA eventually agreed on a valuation that was about…
Continue reading “Price adjustment clause”…

Recent Posts

Guest post on the DTC

The following article on the disability tax credit was written by Tanya O’Connell, a former law clerk at Loukidelis Professional Corporation. The Disability Tax Credit (DTC) The DTC is a personal tax credit available under section 118.3 of the Income…
Continue reading “Guest post on the DTC”…

Inter-company loans

Subsection 15(1) of the Income Tax Act could apply where Aco loans money to Bco and Bco has no means of repaying the money. On the other hand, subsection 246(1) will not apply where Bco and its shareholder have no…
Continue reading “Inter-company loans”…

Change in use and flipping

The CRA has confirmed that a deemed disposition under subsection 45(1) of the Income Tax Act resulting from a change in use is not a disposition for the purposes of the flipping rules in subsections 12(12) and 12(13). See 2024-1027831C6.
Continue reading “Change in use and flipping”…

Swiss bank account trouble

In Azmayesh-Fard v R, 2025 TCC 20, the Court considered whether the CRA had properly reassessed a taxpayer beyond the normal reassessment period and imposed gross negligence penalties for unreported income from a Swiss bank account and for failing to…
Continue reading “Swiss bank account trouble”…

Price adjustment clause

An accounting colleague has reported to me on a CRA audit involving a price adjustment clause. The CRA challenged the valuation used for a transfer of property. The taxpayer and the CRA eventually agreed on a valuation that was about…
Continue reading “Price adjustment clause”…

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Archives

Categories

Recent Posts

Guest post on the DTC

The following article on the disability tax credit was written by Tanya O’Connell, a former law clerk at Loukidelis Professional Corporation. The Disability Tax Credit (DTC) The DTC is a personal tax credit available under section 118.3 of the Income…
Continue reading “Guest post on the DTC”…

Inter-company loans

Subsection 15(1) of the Income Tax Act could apply where Aco loans money to Bco and Bco has no means of repaying the money. On the other hand, subsection 246(1) will not apply where Bco and its shareholder have no…
Continue reading “Inter-company loans”…

Change in use and flipping

The CRA has confirmed that a deemed disposition under subsection 45(1) of the Income Tax Act resulting from a change in use is not a disposition for the purposes of the flipping rules in subsections 12(12) and 12(13). See 2024-1027831C6.
Continue reading “Change in use and flipping”…

Swiss bank account trouble

In Azmayesh-Fard v R, 2025 TCC 20, the Court considered whether the CRA had properly reassessed a taxpayer beyond the normal reassessment period and imposed gross negligence penalties for unreported income from a Swiss bank account and for failing to…
Continue reading “Swiss bank account trouble”…

Price adjustment clause

An accounting colleague has reported to me on a CRA audit involving a price adjustment clause. The CRA challenged the valuation used for a transfer of property. The taxpayer and the CRA eventually agreed on a valuation that was about…
Continue reading “Price adjustment clause”…

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