Ken Griffin and Marc Vanasse, “Income Tax Objection Process” Canadian Tax Highlights 25:3 (March 2017), summarizes the Auditor General’s report on the CRA objection process. Not surprisingly, the report found the process lacking in a number of ways. Objections take too long. The CRA does not learn effectively from the results of objections. In addition, the CRA does not have any standards for resolving objections in a timely manner.
Tax deals re-visited
I wrote previously about Rosenberg v Canada (National Revenue), 2016 FC 1376. Kathryn Walker and Robert G. Kreklewetz “Deals with the CRA” Canadian Tax Highlights 25:3 (March 2017) discusses the cases. After discussing Rosenberg, the authors argue that Galway v…
Bulk Sales Act repealed
The Bulk Sales Act has been repealed with effect from March 22, 2017, the date of Royal Assent for Bill 27, which was enacted as SO 2017, c 2.
LLP negative ACB
Since 2006, the partners of Ontario limited liability partnerships (LLPs) have enjoyed “full shield” protection, which means that they are protected from most liabilities of the partnership except those arising from their own professional negligence. As a result, an LLP…
T1135 for part-year resident
In CRA technical interpretation 2015-0611141E5 (July 11, 2016), the CRA stated that a T1135 filed for a part-year resident should report property and transactions relating to the property for the person’s entire year that includes the time when the person…
VDP Report
The following points summarize the Offshore Compliance Advisory Committee report on the CRA voluntary disclosure program (VDP): Provide less generous relief in certain cases eg where the taxpayer’s default is wilful or deliberate. The conditions for participating in the VDP…
Contribution
Tonight I received the “Outstanding Contribution Award” from the Hamilton Law Association “in recognition of frequent and valued contributions to the bimonthly HLA Journal, Continuing Professional Development programming, and/or HLA practice committees”. My thanks to the Association for this honour.
VDP changes coming?
Neal Armstrong has a good summary of the government’s response to the Sixth Report of the Standing Committee on Finance. It looks like changes are coming to the VDP. Neal Armstrong also has a mischievous sense of humour. He writes…
Negative PUC?
The following is a summary of Marie-Emmanuelle Vaillancourt, “Negative Paid-Up Capital and Subsection 84(4) Reduction”, Tax Topics no. 1894 (June 26, 2008). What are the tax consequences when a corporation purports to reduce tax paid-up capital (PUC) when PUC is…
Trusts and deemed income
Greg A. Leslie, “Trusts — Be Mindful of Allocating Deemed Income!”, Tax Hyperion 13:11 (November 2016) summarizes CRA technical interpretation 2015-0604971E5 (October 19, 2016). How does a trust allocate a deemed gain under s 48.1 of the Income Tax Act…