I presented “Tax Cases of Interest” at the CRA’s quarterly Tax Practitioner’s Consultation Group meeting at the Royal Botanical Gardens this morning.
Demand notes
Lawyers will be familiar with Hare v. Hare, 2006 CanLII 41650, in which the Ontario Court of Appeal held that the limitation period for a demand note began to run with its delivery not with default, much to the consternation…
Objections Tips and Tricks
I’ve written a short article that provides some tips and tricks for preparing a notice of objection.
Disposition
An employee of a corporation owns an option to purchase a share in the capital of the corporation. The corporation decides to amend the terms of the option. Does the amendment have any tax consequences? Maybe.
Nightmare
Unfortunately, with the experience I have working with the CRA, it is only too easy for me to imagine how this might happen: ‘Revenue Canada refuses to pay for million-dollar mistake‘. Wow.
Tiny
I often send links to clients and colleagues by email, but sometimes the links are extremely long and complicated so that they are broken and unusable when they arrive at their destination. That’s where tinyurl.com comes in handy. “http://www.lawtimesnews.com/Headline-News/Record-$169-million-award-will-raise-the-bar” becomes…
Reorgs
Despite the many technical pitfalls in the reorganization provisions of the Income Tax Act, cases involving those provisions do not often come before the Tax Court. Husky Oil Limited v. The Queen, 2009 TCC 118, is one such case that…
Capital dividends and 160
The Tax Court, in Neumann v. The Queen, 2009 TCC 81, has decided that a capital dividend is a transfer of property for the purposes of section 160, just like an ordinary dividend.
Capital Dividends Again
The following article appeared in the latest edition of the Hamilton Law Association Law Journal.
Corrupt
No doubt some taxpayers believe that the CRA is corrupt, but the truth is that most CRA personnel are dedicated and professional civil servants. On the other hand, it’s not necessarily lily-white either.