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LPC Notes (page 47)

Amalgamations and CDA

Posted on: November 11, 2015 Last updated on: November 11, 2015 Written by: John Loukidelis
From question 6 of the 2015 APFF Roundtable, it appears that the positive capital dividend account balance created by Subco’s realization of a capital gain could be paid to Parentco and then to Parentco’s shareholders as a capital dividend even…
Continue reading “Amalgamations and CDA”…

Castro

Posted on: November 6, 2015 Last updated on: November 6, 2015 Written by: John Loukidelis
Craig Burley has written an interesting post on R v Castro, 2015 FCA 225. My summary of Craig’s summary: ouch!
Continue reading “Castro”…

Share attributes

Posted on: November 3, 2015 Last updated on: November 3, 2015 Written by: John Loukidelis
In Neil Armstrong’s summary of a butterfly ruling (2014-0533601R3), he wrote: The reorganization started off in the usual manner with a s. 86 reorg under which the DC shareholders exchanged their old common and preferred shares for special “butterfly” shares…
Continue reading “Share attributes”…

Bike stands

Posted on: November 3, 2015 Last updated on: November 3, 2015 Written by: John Loukidelis
Neil Armstrong notes the following CRA positions on employee benefits from the 2015 APFF Conference: Providing a bike stand area for employees does not confer a benefit if the employees’ usage of it is “difficult to quantify and measure”. Providing…
Continue reading “Bike stands”…

55(2) as a tax reduction tool

Posted on: October 26, 2015 Last updated on: October 26, 2015 Written by: John Loukidelis
The CRA accepts that the GAAR will not apply where a taxpayer deliberately triggers 55(2) to reduce tax. Rather than having Opco pay a dividend to Mr A, Mr A could roll his shares of Opco to Holdco and have…
Continue reading “55(2) as a tax reduction tool”…

NPO T1044 filing requirements

Posted on: October 16, 2015 Last updated on: October 16, 2015 Written by: John Loukidelis
Under s 149(12) of the Income Tax Act (Canada), certain not-for-profits (“NPOs”, ie entities exempt from tax under s 149(1)(l)) must file a T1044 information return. An NPO must file the T1044 if (a) the total of all amounts each…
Continue reading “NPO T1044 filing requirements”…

Collections scam

Posted on: October 10, 2015 Last updated on: October 10, 2015 Written by: John Loukidelis
I have heard recently about a number of taxpayers who received voicemail messages purporting to be from the CRA. The caller left a message threatening the seizure of assets or the immediate imposition of criminal or severe civil sanctions if…
Continue reading “Collections scam”…

Section 51 loss on conversion

Posted on: October 7, 2015 Last updated on: October 7, 2015 Written by: John Loukidelis

Summary of Technical interpretation 2014-0524651I7 E (May 6, 2014).

Continue reading “Section 51 loss on conversion”…

Spousal trust cannot be a GRE

Posted on: September 17, 2015 Last updated on: September 17, 2015 Written by: John Loukidelis
The CRA, in technical interpretation 2014-0553181E5F (June 25, 2015), says that a spousal trust cannot be a “graduated rate estate” for the purposes of the Act.
Continue reading “Spousal trust cannot be a GRE”…

Interest on debt to acquire land; bad debts

Posted on: September 16, 2015 Last updated on: September 16, 2015 Written by: John Loukidelis
Per Lyons J in Kokai-Kuun Estate v R, 2015 TCC 217: a taxpayer cannot add to the cost of vacant land interest and property taxes paid in respect of the land where it was acquired for “investment” purposes but never…
Continue reading “Interest on debt to acquire land; bad debts”…
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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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