The CRA was tardy about publishing the prescribed rates for 2010 Q3. It seems to have wanted to make up for it by publishing the rates for 2010 Q4 early.
Favourite Quote
One of my favourite tax quotes is the following, which was written by the judge in J.F. Newton Ltd. v. Riddell, 45 D.T.C. 5276, 2 C.T.C. 91, 50 B.L.R. 136, 1990 CanLII 933 (BC S.C.), who was forced to…
Auto Expenses
The CRA website now includes a post on the new method for keeping track of motor vehicle expenses.
The HST in Ontario
Do I dare to write about the HST? I don’t, much, because I don’t know much about it. Nonetheless, let me share with you an insight about the Ontario HST that might make your practice life a little easier.
Multiple Classes
The following article appeared in a recent edition of the Hamilton Law Association Law Journal.
Why have separate classes of shares in the capital of a corporation for new investors? Creating separate classes of shares creates its own problems both from a tax and non-tax perspective. Nonetheless, for tax purposes it is sometimes desirable to have different groups of investors subscribe for different classes of shares in the capital of a corporation.
Voluntary Disclosures
I’ve just published a permanent page to my blog on voluntary disclosures.
Tax Wiki
Professor Ben Alarie at the University of Toronto Faculty of Law (my alma mater, I’m proud to say) has started a tax wiki, which is meant to help “Canadians confused with complicated tax laws”.
Bad assets
You need to purify a corporation of its bad assets so that the corporation’s shares will be qualified small business corporation shares for the purposes of the $750,000 capital gains exemption. Let’s assume that you are confident about the values of the assets involved, so that you can leave bad assets with a value equal to exactly 10% of the total gross value of all assets of the corporation. How do you calculate the amount to remove, given that what you remove reduces both the gross value of the bad assets and the gross value of all of the assets of the corporation? The following formula seems to work:
Interest deductibility
A wife pays interest under a line of credit that her husband used to buy shares in a business. Can the wife deduct the interest? Not according to Bernacchi v. The Queen, 2010 TCC 306, unsurprisingly: All in all, I…
Form of notice
In Suffolk v. The Queen, 2010 TCC 295 (an informal procedure case), the Court undertook an interesting review of the caselaw relating to the validity of notices of assessment that contain errors and the form required for a valid notice…