In Marchan v. The Queen, 2008 TCC 158, the taxpayer received stock options from the U.S. parent of the Canadian subsidiary for which he worked in Canada. He exercised the options and sold the underlying securities, but the brokers handling the transactions withheld amounts from his proceeds, presumably on account of U.S. taxes. The taxpayer tried to claim a foreign tax credit.
Another loss
Objection Held in Abeyance
In my post for June 17, I discussed a case allowing interest relief for court-related delay for a taxpayer whose objection was held in abeyance pending the outcome of the court case. In the June 5 Tax Topics, John Yuan points out a potential trap for a taxpayer whose objection is being held in abeyance.
C-50 Now Law
Golf and tax
Interest relief
A Federal Court decision from earlier this year considers whether interest relief should be available to a taxpayer whose objection is held in abeyance pending the outcome of the appeal.
Corporate authorizations
It seems that lately the CRA has been refusing to accept corporate authorization forms (RC59s) signed by anyone other than a director of a corporation. The CRA will refuse to accept the consent unless it is signed by somebody who appears in the “Ontario registry” as a director. What is the CRA up to now?
C-50
Recent cases
Citing the Income Tax Act
Here’s some tax trivia to get us through the month of June. How does one cite the Income Tax Act?