Sometimes taxpayers and their representatives have a hard time understanding the Canadian tax-dispute resolution system, like the poor accountant in Roman Miniotas (Romeo’s Plumbing & Heating) v R, 2011 TCC 43.
Tax Court class actions?
“Government Invites Comments on Proposals to Improve the Caseload Management of the Tax Court of Canada”. From the Finance press release:
Disbursement headache?
PC Employment Agreement
It is our standard practice when incorporating a professional corporation (a PC) to prepare an employment contract between the professional and the PC.
CNFPCA in Force
160 and Knowledge
For the purposes of section 160 of the Income Tax Act, it does not matter whether the transferor or transferee knows that the transferor owes tax at the time of the transfer. What they intend to accomplish by making the transfer is irrelevant as well. In both cases, section 160 will apply, if its other conditions are satisfied. But what about the case where the transferor purports to transfer property to the transferee without her knowledge or consent. In Leclair v Canada, 2011 TCC 323 the court held that section 160 did not apply in those circumstances.
Measuring Employment Benefits
Gifts and Family Law
When the patriarch or matriarch of a family decides to implement a freeze it is quite common for him or her to insist that the gift of the growth shares be excluded from net family property for the purposes of the Family Law Act (Ontario). Are such exclusions effective? McNamee v McNamee, 2011 ONCA 533, illustrates well why lawyers must emphasize to clients that the answer is still a definite “maybe”.