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LPC Notes (page 50)

TCC and FCA odds

Posted on: May 30, 2015 Last updated on: May 30, 2015 Written by: John Loukidelis
From H.M. Dolson, “What To Expect in Tax Adjudication”, Canadian Tax Highlights 23:4 (April 2015): As a whole, a general procedure taxpayer represented by counsel achieved a meaningful victory in 38.5 percent of the published TCC decisions and…
Continue reading “TCC and FCA odds”…

Partnership winding-up

Posted on: May 20, 2015 Last updated on: May 20, 2015 Written by: John Loukidelis
Subsection 85(3) requires that a partnership be wound-up within 60 days after the disposition of property to a corporation under subsection 85(2). The CRA accepts that a partnership has been wound up even if the legal title to real property…
Continue reading “Partnership winding-up”…

Spousal rollover denied

Posted on: May 4, 2015 Last updated on: May 4, 2015 Written by: John Loukidelis
In Murphy Estate v R, 2015 TCC 8, the Tax Court denied the spousal rollover where a consent order issued in the family law context seemed to provide for the transfer of the RRSP to the spouse from the children…
Continue reading “Spousal rollover denied”…

Immigration Tax Issues

Posted on: May 4, 2015 Last updated on: May 4, 2015 Written by: John Loukidelis
Jack Bernstein and Ron Choudhury, in “Immigration into Canada”, Canadian Tax Highlights 23:2 (February 2015), highlight some of the tax issues to be considered in advising a person who is immigrating to Canada.
Continue reading “Immigration Tax Issues”…

Claming ABILs

Posted on: May 4, 2015 Last updated on: May 5, 2015 Written by: John Loukidelis
A husband who is an employee but not a shareholder of Opco cannot claim an ABIL for amounts loaned interest-free to Opco (even though his wife is the sole shareholder of Opco). The husband’s employment income does not mean that…
Continue reading “Claming ABILs”…

Budget 2015 and self-storage

Posted on: April 22, 2015 Last updated on: April 22, 2015 Written by: John Loukidelis
KPMG, in its TaxNewsFlash on the federal budget for 2015, writes the following about the budget promise to review the active business income rules: The budget states that stakeholders have expressed concern about the application of these rules in cases…
Continue reading “Budget 2015 and self-storage”…

74.4(4) Exception Inapplicable

Posted on: April 20, 2015 Last updated on: April 20, 2015 Written by: John Loukidelis
74.4(4) will not apply to save an estate freeze of Opco from the corporate attribution rule where a trust holds shares in Holdco rather than shares in Opco directly. 74.4(4) would also not apply where Opco1 and Opco2 are frozen,…
Continue reading “74.4(4) Exception Inapplicable”…

Worker status and intention

Posted on: April 20, 2015 Last updated on: April 20, 2015 Written by: John Loukidelis
Bruce Russell, in “The Role of Intent in Determining Worker Status” Tax Hyperion 12:3 (March 2015), notes that recent Federal Court of Appeal jurisprudence seems to require a two-step analysis when determining worker status. The first step attempts to ascertain…
Continue reading “Worker status and intention”…

T1135 work

Posted on: April 17, 2015 Last updated on: April 17, 2015 Written by: John Loukidelis
Some tax preparers are reporting that brokerage statements are often inadequate for the purposes of preparing T1135s. An accountant told me that it often takes as long to prepare the T1135 as it does the T1 to which it relates.…
Continue reading “T1135 work”…

Rodents as food

Posted on: April 8, 2015 Last updated on: April 8, 2015 Written by: John Loukidelis
Neal Armstrong, in his summary of technical interpretation 2015-0564611E5, writes as follows: CRA now construes “livestock” more narrowly than as stated in IT-427R, so that it considers that raising rodents qualifies as farming only if they are sold as food…
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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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