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LPC Notes (page 54)

Future income tax assets

Posted on: November 20, 2014 Last updated on: November 20, 2014 Written by: John Loukidelis
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…
Continue reading “Future income tax assets”…

98(3) News

Posted on: November 19, 2014 Last updated on: November 19, 2014 Written by: John Loukidelis
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…
Continue reading “98(3) News”…

Diverted funds

Posted on: November 18, 2014 Last updated on: November 18, 2014 Written by: John Loukidelis

Neal Armstrong has written a wonderfully sarcastic case comment on Dimane Enterprises Ltd. v R, 2014 TCC 334.

Continue reading “Diverted funds”…

Brogan

Posted on: November 11, 2014 Last updated on: February 3, 2022 Written by: John Loukidelis
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…
Continue reading “Brogan”…

Spousal trust issues

Posted on: November 2, 2014 Last updated on: November 2, 2014 Written by: John Loukidelis

Colleen Ma, in Canadian Tax Focus 4:3 (August, 2014) summarizes some issues with spousal trusts:

Continue reading “Spousal trust issues”…

Portrait of the Tax Nerd as a Middle-aged Man

Posted on: October 29, 2014 Last updated on: October 29, 2014 Written by: John Loukidelis
I noticed today that the clauses in subparagraph 256(7)(a)(i) of the Income Tax Act (Canada) are missing a conjunction. David Sherman and his team confirmed that Parliament enacted amendments to the subparagraph that omitted the conjunction. In fact, there should…
Continue reading “Portrait of the Tax Nerd as a Middle-aged Man”…

Ponzi schemes, again

Posted on: October 26, 2014 Last updated on: October 26, 2014 Written by: John Loukidelis
In Roszko v R, 2014 TCC 59, the Court held that amounts received by a participant under notes issued as part of a Ponzi scheme were not income for the purposes of the Income Tax Act (Canada). The Court distinguished…
Continue reading “Ponzi schemes, again”…

Inter-company Management Fees

Posted on: October 26, 2014 Last updated on: October 26, 2014 Written by: John Loukidelis
A detailed services agreement was not enough by itself to justify the deduction of management fees paid by Opco to Holdco. The court wanted evidence of the services rendered, the service hours provided, the hourly rate and the identity of…
Continue reading “Inter-company Management Fees”…

Providing space

Posted on: October 20, 2014 Last updated on: October 20, 2014 Written by: John Loukidelis
Craig Burley has blogged about 0742443 BC Ltd v R, 2014 TCC 301. His takeaway on the case? “If you have a business that incorporates any sort of rental of space, or allowing customers to use your space, I recommend…
Continue reading “Providing space”…

HST diversion

Posted on: October 16, 2014 Last updated on: October 16, 2014 Written by: John Loukidelis
The CRA just tweeted “Is the GST number on your invoice valid? Find out by using the GST/HST registry at http://t.co/LCmyRdCTqQ #GST #HST”. I’ve posted about the registry before, but why would you bother to check? You would care because,…
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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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