The CRA has published a new folio on amalgamations here.
Tax simplification
John Manley, speaking at the Canadian Tax Foundation‘s national conference yesterday, made the case for tax simplification. To which I say “Hah!” I’m just waiting for the “My grandfather was a Greek immigrant who ran a restaurant in North Bay…
HST and damages
Greg Sawatsky has written a helpful summary of the HST rules applying to certain payments of damages.
Objections Can Result in a Bigger Tax Bill
The CRA takes the position that an Appeals officer can issue a reassessment that increases a tax liability if new information supporting the increase comes to light as part of the objection process. Amanda Doucette, “Filing a Notice of Objection…
Loss Carrybacks and Reassessments
Alex Klyguine reminds us that, if the CRA reassesses a year and the taxpayer wishes to dispute the reassessment, the taxpayer must be cautious about applying losses of other years to reduce the taxable income of the reassessed year. If…
Future income tax assets
The CRA takes the position that a future income tax asset it not an asset for the purposes of the QSBCS and SBC definitions. Such an asset should be ignored when determining whether a share is a QSBCS or a…
98(3) News
Neal Armstrong is on a sarcasm roll this week. After noting that the CRA, in a recent interpretation (2014-0540611E5E), took the position that a 98(3) election is valid only if it is made for all property of the partnership and…
Diverted funds
Neal Armstrong has written a wonderfully sarcastic case comment on Dimane Enterprises Ltd. v R, 2014 TCC 334.
Brogan
Craig Burley has written a brief summary of Canada (Atty-General) v Brogan Family Trust, 2014 ONSC 6354, a recent case on rectification. I’m skeptical of the idea that the CRA has no interest in a rectification application if it is…
Spousal trust issues
Colleen Ma, in Canadian Tax Focus 4:3 (August, 2014) summarizes some issues with spousal trusts: