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LPC Notes (page 40)

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…
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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…
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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…
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You’d better calculate safe income

Posted on: December 2, 2016 Last updated on: December 2, 2016 Written by: John Loukidelis
The CRA appeared unsympathetic to the idea that detailed calculations of safe income might not be necessary where Opco is wholly-owned by Holdco, and Opco accounting income does not differ greatly from its taxable income. The CRA representative spoke darkly…
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Discretionary dividend shares

Posted on: December 2, 2016 Last updated on: December 2, 2016 Written by: John Loukidelis
Suppose shareholders of Opco hold different classes of common shares on which dividends can be paid at the discretion of the board so that one class can receives dividends to the exclusion of other classes. All common shares participate pro…
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Trust that avoids 21-year rule subject to GAAR

Posted on: December 2, 2016 Last updated on: December 2, 2016 Written by: John Loukidelis
An inter vivos trust is approaching its 21-year anniversary. Before the anniversary, the trust distributes property under 107(2) to Canco, a corporate beneficiary, which is wholly-owned by another inter vivos trust. The other trust was just formed, and so it…
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Real property registry

Posted on: November 26, 2016 Last updated on: November 26, 2016 Written by: John Loukidelis
The Business Corporations Act (Ontario) (the “OBCA”) is being amended effective December 10, 2016, to require a corporation incorporated or continued under the OBCA to maintain a “register of ownership interests in land in Ontario”. The register must identify each…
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What is a nil assessment?

Posted on: November 24, 2016 Last updated on: November 24, 2016 Written by: John Loukidelis
In Shreedhar v R, 2016 TCC 254, the Crown brought a motion to strike an informal procedure appeal. The Crown claimed that the taxpayer was attempting to appeal from a nil assessment. The Court disagreed because, while the assessment had…
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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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