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LPC Notes (page 40)

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”…

No rollover for voluntary dispositions of farm quota

Posted on: December 19, 2016 Last updated on: December 19, 2016 Written by: John Loukidelis
In technical interpretation 2016-0666901E5, the CRA was asked whether the new rules applicable to farm quota after 2016 will provide for a rollover equivalent to the one found in s 14(6) of the ITA for voluntary dispositions of quota. The…
Continue reading “No rollover for voluntary dispositions of farm quota”…

Agreement not to audit

Posted on: December 16, 2016 Last updated on: December 16, 2016 Written by: John Loukidelis
Neal Armstrong reports that the Federal Court has ruled that an agreement concluded by one auditor not to further audit a taxpayer is binding on the CRA. See Rosenberg v MNR, 2016 FC 1376. I have not been able to…
Continue reading “Agreement not to audit”…

S 55(2.1)(b)(ii)(B) and cash

Posted on: December 3, 2016 Last updated on: December 3, 2016 Written by: John Loukidelis
According to the CRA, cash is property for the purposes of the application of s 55(2.1)(b)(ii)(B). 2016 CTF Roundtable Q8. S 55(2.1)(b) reads as follows: (b) it is the case that (i) one of the purposes of the payment or…
Continue reading “S 55(2.1)(b)(ii)(B) and cash”…

RRSP/RRIF/TFSA “advantages”

Posted on: December 3, 2016 Last updated on: December 3, 2016 Written by: John Loukidelis
The CRA believes that an annuitant who pays fees (investment management and other fees) for an RRSP/RRIF/TFSA thereby derives an “advantage”. The CRA says that, with effect after 2017, plans must be changed so that the fees are charged to…
Continue reading “RRSP/RRIF/TFSA “advantages””…

More s 55 hocus pocus

Posted on: December 3, 2016 Last updated on: December 3, 2016 Written by: John Loukidelis
Holdco owns all of Opco’s issued shares. Both corporations have calendar year-ends. Opco doesn’t have any safe income, but it has $383,333 of RDTOH. Opco pays a $1 million dividend to Holdco, which pays a $1 million dividend to its…
Continue reading “More s 55 hocus pocus”…
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Canada Child Benefit and Shared Custody

In Wong v R, 2025 TCC 24 (informal procedure), Mr Justice Bocock provided a helpful road map of the surprisingly complicated rules relating to shared custody and entitlement to the Canada Child Benefit.
Continue reading “Canada Child Benefit and Shared Custody”…

Misdirected assessment

Poor Mr Lam trusted his tenant to forward important mail while Mr Lam was out of the country, but the tenant left a 2016 HST assessment in a pile of junk mail. Mr Lam didn’t become aware of the assessment…
Continue reading “Misdirected assessment”…

50-50 shareholders and s 160; directors and independent contractors

McCague v R, 2025 TCC 59, is another section 160 case where 50/50 shareholders caused their corporation to pay them dividends at a time when it owed taxes. The Court held that section 160 applied and summarized the law in…
Continue reading “50-50 shareholders and s 160; directors and independent contractors”…

Preliminary vs preparatory expenses

In Lienaux v R, 2025 TCC 67 (informal procedure), the Court referred to Vesuna v R, 2022 FCA 58, and Gartry v R, 1994 CanLII 19352 (TCC), in denying expenses incurred where the taxpayer had not actually started to carry…
Continue reading “Preliminary vs preparatory expenses”…

Negligence for not reviewing return

In 994552 N.W.T. Ltd. v R, 2025 TCC 55, Mr Justice Bocock considered whether the taxpayer corporation was liable to be reassessed beyond the normal reassessment period for two taxation years and for gross negligence penalties for overclaimed capital cost…
Continue reading “Negligence for not reviewing return”…

Recent Posts

Canada Child Benefit and Shared Custody

In Wong v R, 2025 TCC 24 (informal procedure), Mr Justice Bocock provided a helpful road map of the surprisingly complicated rules relating to shared custody and entitlement to the Canada Child Benefit.
Continue reading “Canada Child Benefit and Shared Custody”…

Misdirected assessment

Poor Mr Lam trusted his tenant to forward important mail while Mr Lam was out of the country, but the tenant left a 2016 HST assessment in a pile of junk mail. Mr Lam didn’t become aware of the assessment…
Continue reading “Misdirected assessment”…

50-50 shareholders and s 160; directors and independent contractors

McCague v R, 2025 TCC 59, is another section 160 case where 50/50 shareholders caused their corporation to pay them dividends at a time when it owed taxes. The Court held that section 160 applied and summarized the law in…
Continue reading “50-50 shareholders and s 160; directors and independent contractors”…

Preliminary vs preparatory expenses

In Lienaux v R, 2025 TCC 67 (informal procedure), the Court referred to Vesuna v R, 2022 FCA 58, and Gartry v R, 1994 CanLII 19352 (TCC), in denying expenses incurred where the taxpayer had not actually started to carry…
Continue reading “Preliminary vs preparatory expenses”…

Negligence for not reviewing return

In 994552 N.W.T. Ltd. v R, 2025 TCC 55, Mr Justice Bocock considered whether the taxpayer corporation was liable to be reassessed beyond the normal reassessment period for two taxation years and for gross negligence penalties for overclaimed capital cost…
Continue reading “Negligence for not reviewing return”…

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Archives

Categories

Recent Posts

Canada Child Benefit and Shared Custody

In Wong v R, 2025 TCC 24 (informal procedure), Mr Justice Bocock provided a helpful road map of the surprisingly complicated rules relating to shared custody and entitlement to the Canada Child Benefit.
Continue reading “Canada Child Benefit and Shared Custody”…

Misdirected assessment

Poor Mr Lam trusted his tenant to forward important mail while Mr Lam was out of the country, but the tenant left a 2016 HST assessment in a pile of junk mail. Mr Lam didn’t become aware of the assessment…
Continue reading “Misdirected assessment”…

50-50 shareholders and s 160; directors and independent contractors

McCague v R, 2025 TCC 59, is another section 160 case where 50/50 shareholders caused their corporation to pay them dividends at a time when it owed taxes. The Court held that section 160 applied and summarized the law in…
Continue reading “50-50 shareholders and s 160; directors and independent contractors”…

Preliminary vs preparatory expenses

In Lienaux v R, 2025 TCC 67 (informal procedure), the Court referred to Vesuna v R, 2022 FCA 58, and Gartry v R, 1994 CanLII 19352 (TCC), in denying expenses incurred where the taxpayer had not actually started to carry…
Continue reading “Preliminary vs preparatory expenses”…

Negligence for not reviewing return

In 994552 N.W.T. Ltd. v R, 2025 TCC 55, Mr Justice Bocock considered whether the taxpayer corporation was liable to be reassessed beyond the normal reassessment period for two taxation years and for gross negligence penalties for overclaimed capital cost…
Continue reading “Negligence for not reviewing return”…

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