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LPC Notes (page 48)

Personal services business

Posted on: September 15, 2015 Last updated on: September 15, 2015 Written by: John Loukidelis
C.J. McCarty Inc. v R, 2015 TCC 201, is a good recent analysis of whether the personal services business rules applied to a taxpayer in light of Wiebe Door and Sagaz. Bruce Russell, “McCarty – A Personal Services Business?” Tax…
Continue reading “Personal services business”…

Shareholder agreements and de jure control

Posted on: September 15, 2015 Last updated on: September 15, 2015 Written by: John Loukidelis
Will a shareholder agreement that permits a minority shareholder to elect the majority of the corporation’s board confer control on the minority shareholder? The Tax Court in Kruger Wayagamack Inc. v R, 2015 TCC 90, said not if the minority…
Continue reading “Shareholder agreements and de jure control”…

Stock options and death

Posted on: September 15, 2015 Last updated on: September 15, 2015 Written by: John Loukidelis
From Andrew Morreale, “Stock Option Deduction Is Available on Death” Canadian Tax Focus 5:3 (August 2015): An employment benefit in respect of unexercised employee stock options that arises on death is eligible for the paragraph 110(1)(d) deduction through the use…
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Alberta trust vindicated

Posted on: September 15, 2015 Last updated on: September 15, 2015 Written by: John Loukidelis
What does it take to make an Alberta trust “work” in light of Fundy Settlement v Canada, 2012 SCC 14? From Colin Poon, “Interprovincial Tax Planning Using Trusts Upheld”, Canadian Tax Focus 5:3 (August 2015) re Discovery Trust v Canada…
Continue reading “Alberta trust vindicated”…

Crooked preparer jail

Posted on: September 13, 2015 Last updated on: September 13, 2015 Written by: John Loukidelis
I’ve complained before about crooked preparers who file false expense or donation claims for (sometimes) clueless taxpayers. The taxpayers get the refund, pay the preparer’s fee (which is often pretty generous) and then are reassessed for the bogus claims (with…
Continue reading “Crooked preparer jail”…

CRA charity nonsense—it’s insidious

Posted on: September 8, 2015 Last updated on: September 8, 2015 Written by: John Loukidelis
Craig Burley is Unhappy about a recent CRA advisory on registered charities and partisan political activities, which advisory includes the following gem: When a charity invites comments on its website, blogs, or on social media, it should monitor them for…
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Two HST items

Posted on: August 29, 2015 Last updated on: August 29, 2015 Written by: John Loukidelis
I stay away from HST matters generally because it is an area that is more than complicated enough to merit its own specialists. Accordingly, I don’t blog about HST much, but here are two items worth looking at: Jennifer Muirhead,…
Continue reading “Two HST items”…

SCC dismisses Guindon appeal

Posted on: July 31, 2015 Last updated on: July 31, 2015 Written by: John Loukidelis

The Supreme Court has dismissed the taxpayer’s appeal in Guindon v R, 2015 SCC 41.

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Delle Donne v HMQ

Posted on: July 16, 2015 Last updated on: July 16, 2015 Written by: John Loukidelis
The Financial Post has a report in it today on Delle Donne v R, 2015 TCC 150, in which yours truly acted as counsel for the taxpayer. Translation of Bill Innes’ comment in the Post article: even a chimp could…
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Accounting proposal postponed

Posted on: July 15, 2015 Last updated on: July 15, 2015 Written by: John Loukidelis
KPMG reports that the implementation of a proposal to require corporations to treat typical freeze shares as debt (with an offsetting special debit to equity) for financial statement purposes has been postponed to January 1, 2018 (from January 1, 2016).
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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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