• Skip to main navigation
  • Skip to main content
  • Skip to footer
Loukidelis PC

Loukidelis PC

Effective. Accessible. Responsive

  • Services
  • Team
  • LPC Notes
  • Articles
  • Privacy Policy
  • Contact Us
  • Disclaimer
  • Skip to menu toggle button

LPC Notes (page 62)

Income averaging?

Posted on: December 15, 2012 Last updated on: December 15, 2012 Written by: John Loukidelis

Mark Hunter pointed out to me that paragraph 20(1)(j) of the Income Tax Act (Canada) doesn’t work well as an income-averaging tool if used in circumstances where the person taking the loan can’t repay it any time soon or will do so in a year without much income.

Continue reading “Income averaging?”…

Donation tax shelter case

Posted on: December 12, 2012 Last updated on: December 12, 2012 Written by: John Loukidelis

Hamilton’s own Mr Justice Randall Bocock goes head-to-head with Maréchaux in Berg v R, 2012 TCC 406.

Continue reading “Donation tax shelter case”…

Estate planning and personal use real property

Posted on: November 21, 2012 Last updated on: November 21, 2012 Written by: John Loukidelis
I just listened to a helpful presentation on estate planning for personal use real property by Robin MacKnight at the Law Society’s seminar on “Taxation Issues in Real Estate Transactions“.
Continue reading “Estate planning and personal use real property”…

Subsection 83(2.1) applied

Posted on: November 11, 2012 Last updated on: November 11, 2012 Written by: John Loukidelis
In Groupe Honco inc. c R, 2012 CCI 305, the Tax Court applied the anti-avoidance rule in subsection 83(2.1) to a dividend purported to be paid from the capital dividend account of a corporation taken over by another so that…
Continue reading “Subsection 83(2.1) applied”…

No rectification necessary

Posted on: November 11, 2012 Last updated on: November 11, 2012 Written by: John Loukidelis
In Twomey v R, 2012 TCC 310, the taxpayer thought he had been issued 100 Common Shares in the capital of a corporation, but the minute book indicated he had received only one. The difference mattered: whether the taxpayer could…
Continue reading “No rectification necessary”…

Guindon appealed

Posted on: November 1, 2012 Last updated on: November 1, 2012 Written by: John Loukidelis
The Crown filed its appeal in Guindon yesterday.
Continue reading “Guindon appealed”…

Family Law and the ITA

Posted on: October 16, 2012 Last updated on: October 16, 2012 Written by: John Loukidelis

Folks, just a reminder that the parties to a family law dispute, even with the assistance of an order of the Ontario Superior Court of Justice, cannot override the rules in the Income Tax Act respecting the taxation of support amounts.

Continue reading “Family Law and the ITA”…

Johnson appeal allowed

Posted on: October 11, 2012 Last updated on: October 11, 2012 Written by: John Loukidelis

The Federal Court of Appeal has allowed the Crown’s appeal in Johnson: see R v Johnson, 2012 FCA 285, rev’g 2011 TCC 540.

Continue reading “Johnson appeal allowed”…

Third-party penalties case

Posted on: October 9, 2012 Last updated on: October 9, 2012 Written by: John Loukidelis
Last week, the Tax Court released its decision in Guindon v R, 2012 TCC 287, in which the court concluded that the third-party penalties provided by section 163.2 of the Income Tax Act are criminal in nature and that the…
Continue reading “Third-party penalties case”…

Audit process

Posted on: October 7, 2012 Last updated on: October 7, 2012 Written by: John Loukidelis
The next issue of the Hamilton Law Association Journal will contain an article I’ve written on the audit process and a taxpayer’s liability under the Income Tax Act.
Continue reading “Audit process”…
« Previous page 1 … 60 61 62 63 64 … 107 Next page »

Archives

Categories

Recent notes

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”…

Archives

Categories

Meta

  • Log in
  • Entries feed
  • Comments feed
  • WordPress.org

About this site

Click here for an important disclaimer about this site.

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”…

© Loukidelis Professional Corporation