In Canada Trustco Mortgage Company v. The Queen, 2008 TCC 482, aff’d 2009 FCA 267, the Tax Court held that a financial institution must comply with a requirement to pay even where the the funds sought to be seized from the institution were held in a lawyer’s trust account.
Audit headlines
It’s not often that a CRA audit makes headlines: Canada Revenue probe focuses on some RBC DS clients.
Retail Loses Again
Taxpayers who participated in ‘retail’ donation tax shelters continue to fare poorly in the Tax Court. See Maréchaux v. The Queen, 2009 TCC 587.
Triangles
Don’t forget the triangular amalgamation. While these types of amalgamations are more typical in the public company context, they can be a useful tool for private company deals too.
Eligible Dividends
Last week, I gave a presentation for the Hamilton Law Association on eligible dividends at its annual Corporate Commercial update. You can find a copy of a sample resolution for eligible dividends here. Use at your own risk!
Zapper
The CRA is attempting to hunt down store owners who install software that “suppresses” records of cash sales made through a cash register. Maybe that’s an argument for making a voluntary disclosure now. Visit the taxman before he visits you.
Tax for Trusts
The following article will appear in an upcoming edition of the Hamilton Law Association Law Journal.
Freeze Shares
The following article appeared in the latest edition of the Hamilton Law Association Law Journal.
Records
The latest edition of Taylor Leibow‘s Business Matters has an interesting article about record-keeping and the preparation of death returns. The article points out that poor record-keeping can be problematic in a tax system that expects taxpayers to prove they…
Valuation redux
In a post I wrote about a year ago, I complained about the CRA’s then-recent pronouncements on control premiums. The CRA, at the most recent Canadian Tax Foundation BC Conference, recanted this position, at least in part, as follows: