Paul Hickey, in Canadian Tax Highlights (22:3, March 2014), notes that the CRA recently confirmed that it will defer processing an election to treat an excess capital dividend as a separate taxable dividend until any related objection under Part III…
Guilty pleas and the Tax Court
James Rhodes, in a recent post on the Canadian Tax Professionals group on LinkedIn, drew our attention to McIntrye v R, 2014 TCC 111, in which Justice Diane Campbell, among other things, found that the CRA was not bound by an agreed statement of facts (ASF) arrived at as part of a plea bargain and that the CRA, in assessing the taxpayers, was not required to make assumptions that were consistent with the ASF.
PAC Update
As noted previously on this blog, the CRA updated its Income Tax Folio S4-F3-C1 on price adjustment clauses (PACs) in January. I’ll probably do a longer post later on how this folio updates the CRA’s IT bulletin on PACs. For…
CRA Update of Principal Residence Folio
The CRA has updated Income Tax Folio Chapter S1-F3-C2, Principal Residence.
CRA Netfile Down
From Craig Burley’s Twitter feed today: CRA and Heartbleed: http://craigburley.com/?p=47. “Change your passwords” is the general advice. CRA website login services are shuttered for now.
Another tax fraud?
From the “Here We Go Again” file: according to an RCMP news release he RCMP’s Greater Toronto Area (GTA) Financial Crime team has arrested and charged six people after thousands of investors and the Government of Canada lost millions of…
Typography for Lawyers
I have an interest in typography based in a belief that, because our work product so often consists of the documents we produce (at least in the eyes of our clients), we lawyers should take extra care with the appearance…
Housing Loans
Owner-managers and their advisers need to be wary of housing loans made to a private corporation’s controlling shareholder. In Mast v R, 2013 TCC 309, the Tax Court concluded that the exception to subsection 15(2) of the Income Tax Act…
Minute books
Too often, corporate minute books are taken for granted by their officers, directors and shareholders. My post earlier today reminded me that the problem to which it alludes often stems from a minute book that hasn’t been maintained properly. As…
Paying dividends, again
Neal Armstrong makes note of a recent CRA technical (French only), which confirms that the CRA might not recognize an amount supposedly “paid” as a dividend if it is supported only by accounting journal entries. The well-established principle, per Hickman…