Bryan Walters has drawn my attention to an interesting CRA technical interpretation (2011-0404641C6 or CCH Window ¶10,832) in which the CRA states that the provisions of a shareholder agreement might reduce the value of freeze shares that otherwise have the “right” attributes for the purposes of a freeze (see “Freeze Shares“).
55(2)-land
I didn’t understand CRA technical interpretation 2011-0394191 at first, but I think I get it now.
Goodwill and estate planning
Mark Brohman at Durward Jones Barkwell was kind enough to send to me a reminder in the form of a technical interpretation of a very important fact about goodwill and estate planning.
Corollary
In Vankerk v R, 2006 FCA 96 (which I wrote about here), the Court held that a taxpayer could not deduct a loss incurred in connection with an “investment” in a business that turned out to be a fraud. A…
Donation tax shelter class action
For an article on donation tax shelter class actions, click here.
Tax protesters redux (ridiculous more like)
The CRA is warning Canadians to stay away from the tax protest movement, again. I can’t believe people are still falling for this crap given that, as the CRA release points out, “Canadian courts have repeatedly and consistently rejected all…
CRA News
The CRA issued a couple of interesting technical interpretations in the last few months. Foreign Entity Classification The CRA will no longer issue technical interpretations on foreign entity classification (CRA technical dated August 04, 2011, 2011-0415141E5) because whether the foreign…
Fuzzy logic
Is a gain realized on a sale of real property a capital gain or must it be fully included in income, perhaps because the sale was in connection with an “adventure in the nature of trade”? One might think that…
The Arnold Report
Brian Arnold maintains a blog of sorts over at the CTF website. I say “of sorts” not to denigrate what he does with his posts—which are always informative and often quite funny—but to point out that when you number your…
Acting in concert
Two unrelated individuals each own 50% of a corporation. If the daughter of one of them is an employee of the corporation, does she deal with it at arm’s length for the purposes of subsection 5(2) of the Employment Insurance…