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LPC Notes (page 39)

VDP changes coming?

Posted on: February 28, 2017 Last updated on: February 28, 2017 Written by: John Loukidelis
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…
Continue reading “VDP changes coming?”…

Negative PUC?

Posted on: February 18, 2017 Last updated on: February 18, 2017 Written by: John Loukidelis
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…
Continue reading “Negative PUC?”…

Trusts and deemed income

Posted on: February 6, 2017 Last updated on: February 6, 2017 Written by: John Loukidelis
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…
Continue reading “Trusts and deemed income”…

De facto arm’s length

Posted on: January 21, 2017 Last updated on: January 21, 2017 Written by: John Loukidelis
Marissa Halil and Manu Kakkar, “Section 84.1 and Factual Non-Arm’s-Length Considered” Tax for the Owner-Manager 17:1 (January 2017) summarizes Poulin v R, 2016 TCC 154, in which the Court held that conflict between parties and hard bargaining does not mean…
Continue reading “De facto arm’s length”…

GAAR and corporate surplus

Posted on: January 21, 2017 Last updated on: January 21, 2017 Written by: John Loukidelis
In Pomerleau c R, 2016 CCI 228, the Tax Court applied GAAR to a series of transactions that used the stop loss rule in 40(3.6) to create basis not caught by the PUC grind in 84.1, which in turn allowed…
Continue reading “GAAR and corporate surplus”…

Shareholder agreements and the SBD

Posted on: January 5, 2017 Last updated on: January 5, 2017 Written by: John Loukidelis
Jack Bernstein, “Buy-Sell Provisions and Association” Canadian Tax Highlights 24:11 (Nov 2016), is a useful supplement to my post on the subject.
Continue reading “Shareholder agreements and the SBD”…

TPSs and PACs

Posted on: January 5, 2017 Last updated on: January 5, 2017 Written by: John Loukidelis
The CRA has previously stated that a deemed dividend arising on the redemption of a taxable preferred share (TPS) for a “specified amount” will not be an excluded dividend for the purposes of Part VI.1 of the Income Tax Act…
Continue reading “TPSs and PACs”…

Borrowing from RRSP to loan to Opco

Posted on: January 5, 2017 Last updated on: January 5, 2017 Written by: John Loukidelis
If the technical requirements of the Income Tax Act (Canada) are met, a taxpayer can mortgage her house to her RRSP and then deduct the interest on the loan from the RRSP, if the loan proceeds are on-loaned to Opco.…
Continue reading “Borrowing from RRSP to loan to Opco”…

Self-assessing GAAR?

Posted on: January 5, 2017 Last updated on: January 5, 2017 Written by: John Loukidelis
In Quinco Financial Inc v R, 2016 TCC 190, Justice Bocock held that interest on a GAAR assessment accrues from the balance due date, just like any other assessment. His Honour, however, in obiter, also stated that a taxpayer has…
Continue reading “Self-assessing GAAR?”…

Corporate gifts

Posted on: December 23, 2016 Last updated on: December 23, 2016 Written by: John Loukidelis
Neal Armstrong reports that the Quebec Court of Appeal, in Emballages Starflex Inc. v Agence du revenu du Québec, 2016 QCCA 1856, has held that a corporation cannot deduct a gift to a charity as a business or promotional expense.…
Continue reading “Corporate gifts”…
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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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