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LPC Notes (page 45)

A simpler T1135

Posted on: February 8, 2016 Last updated on: February 8, 2016 Written by: John Loukidelis
My thanks to Fred Buzzelli, who sent me a link to a good article by Gabe Hayos on the simplified T1135.
Continue reading “A simpler T1135”…

Are step children related?

Posted on: February 2, 2016 Last updated on: February 2, 2016 Written by: John Loukidelis
Mr X and Ms Y are common law partners. Each of them has a son from a previous relationship. Are the sons related for the purposes of the Income Tax Act (Canada)? The CRA says “yes” because the step brothers…
Continue reading “Are step children related?”…

Misrepresentation

Posted on: January 27, 2016 Last updated on: January 27, 2016 Written by: John Loukidelis
From Justice Bocock, in Robertson v R, 2015 TCC 246, we read the following regarding whether a mistake of law amounts to a negligent misrepresentation: wise and prudent person is, generally by definition, not unknowledgeable of the law. However,…
Continue reading “Misrepresentation”…

No refund for you

Posted on: January 27, 2016 Last updated on: January 27, 2016 Written by: John Loukidelis
A corporate payor doesn’t get a refund if it pays a dividend but fails to file its tax return for the year within three years. But at least RDTOH isn’t reduced either. See Dino Infanti, “FCA Agrees: Dividend Refund Timed…
Continue reading “No refund for you”…

55(2) This Week

Posted on: January 27, 2016 Last updated on: January 27, 2016 Written by: John Loukidelis
Manu Kakkar and Marissa Halil, in “Subsection 55(2): The CRA’s Recent Positions” Tax for the Owner-Manager 16:1 (January 2016), provide a useful summary of the CRA’s pronouncements on 55(2) at the Tax Foundation conference. The CRA is concerned that deliberately…
Continue reading “55(2) This Week”…

Neutral citation for PITA

Posted on: January 22, 2016 Last updated on: January 22, 2016 Written by: John Loukidelis
Carswell is making the Practitioner’s Income Tax Act (PITA) even more useful by switching to neutral citations for its case references. The neutral citation provides a sure-fire way to locate a case quickly and easily, regardless of the database you…
Continue reading “Neutral citation for PITA”…

Payments to non-residents

Posted on: January 13, 2016 Last updated on: January 13, 2016 Written by: John Loukidelis
The CRA concluded that Canco was not required to withhold from incentive amounts paid to the non-resident employees of dealers of Canco’s profits. The incentive amounts amounts related to warranties registered on Canco’s products. The CRA, however, stated that Canco…
Continue reading “Payments to non-residents”…

Car logo

Posted on: January 13, 2016 Last updated on: January 13, 2016 Written by: John Loukidelis
The CRA takes the view that a section 6 standby charge is not reduced by a contract of employment that requires the employee to drive a company car at all times, even for personal use, where the car is decorated…
Continue reading “Car logo”…

Run-off insurance

Posted on: January 13, 2016 Last updated on: January 13, 2016 Written by: John Loukidelis
From CRA technical interpretation 2015-0618981E5 dated December 3, 2015: enerally speaking, the fact a taxpayer no longer carries on a business will not preclude the taxpayer from deducting Run-off Insurance premiums in the year they are paid, provided the insurance…
Continue reading “Run-off insurance”…

Deposit forfeited to non-resident vendor

Posted on: January 4, 2016 Last updated on: January 4, 2016 Written by: John Loukidelis
From Georgina Tollstam, “Deposit Forfeited to Non-Resident” Canadian Tax Highlights 23:6 (June 2015): An internal technical interpretation (2013-0479861I7, March 16, 2015) confirms that if a Canadian taxpayer purchases real property located in Canada from a non-resident vendor and the sales…
Continue reading “Deposit forfeited to non-resident vendor”…
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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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