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LPC Notes (page 94)

Rights and an Ombudsman

Posted on: May 28, 2007 Last updated on: May 28, 2007 Written by: John Loukidelis
A CRA press release just announced a “new” Taxpayer Bill of Rights (isn’t that old news?) and the creation of a Taxpayers’ Ombudsman. I can just imagine the paper piling up at the latter’s office within about 15 seconds of…
Continue reading “Rights and an Ombudsman”…

LLCs

Posted on: May 24, 2007 Last updated on: May 24, 2007 Written by: John Loukidelis

Last week’s CCH Tax Topics has an interesting article on limited liability companies (LLCs) in light of the B.C. Supreme Court’s decision in Boliden Westmin Ltd. et al. v. The Queen, 2007 BCSC 351.

Continue reading “LLCs”…

Bill C-52 Update

Posted on: May 16, 2007 Last updated on: May 16, 2007 Written by: John Loukidelis
Bill C-52 received second reading yesterday and was referred to committee.
Continue reading “Bill C-52 Update”…

Bill C-33 update

Posted on: May 15, 2007 Last updated on: May 15, 2007 Written by: John Loukidelis
Bill C-33 has received second reading and has been referred to committee.
Continue reading “Bill C-33 update”…

Ontario Corporations Act Update

Posted on: May 11, 2007 Last updated on: May 11, 2007 Written by: John Loukidelis
The Ontario government has announced that it “is undertaking a project to review and reform the Ontario Corporations Act (CA)”. The government is inviting “comments and suggestions from stakeholders and from the public regarding the reform of this important legislation.”
Continue reading “Ontario Corporations Act Update”…

Charity Law Symposium

Posted on: May 10, 2007 Last updated on: May 10, 2007 Written by: John Loukidelis
I spoke about split receipts at the Canadian Bar Association’s National Charity Law Symposium in Toronto today. You can download my presentation here. You can also download a “decision tree” that highlights the issues to be considered in issuing split…
Continue reading “Charity Law Symposium”…

Redeemer Goes to Ottawa

Posted on: May 10, 2007 Last updated on: May 10, 2007 Written by: John Loukidelis
The Supreme Court of Canada today granted Redeemer Foundation’s “application for leave to appeal with costs to the applicant in any event of the cause.” The plot thickens. For my comments on this case, search for “Redeemer” on this…
Continue reading “Redeemer Goes to Ottawa”…

Debate on Bill C-33

Posted on: May 5, 2007 Last updated on: May 5, 2007 Written by: John Loukidelis

The House of Commons is now debating Bill C-33 at second reading. You can get the flavour of the debate by reading the speech of Mr. Massimo Pacetti (Saint-Léonard—Saint-Michel, Lib.), which reads in part:

Continue reading “Debate on Bill C-33”…

Voluntary disclosure update

Posted on: May 5, 2007 Last updated on: May 5, 2007 Written by: John Loukidelis
The CRA has posted an update on its no-names voluntary disclosure program.
Continue reading “Voluntary disclosure update”…

Trouble for a charity

Posted on: April 30, 2007 Last updated on: April 30, 2007 Written by: John Loukidelis
I reported on a tax case involving All Saints Greek Orthodox Church here. Now the Toronto Star is reporting that the church issued receipts with a total value of about $273 million as part of the program under audit in…
Continue reading “Trouble for a charity”…
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Guest post on the DTC

The following article on the disability tax credit was written by Tanya O’Connell, a former law clerk at Loukidelis Professional Corporation. The Disability Tax Credit (DTC) The DTC is a personal tax credit available under section 118.3 of the Income…
Continue reading “Guest post on the DTC”…

Inter-company loans

Subsection 15(1) of the Income Tax Act could apply where Aco loans money to Bco and Bco has no means of repaying the money. On the other hand, subsection 246(1) will not apply where Bco and its shareholder have no…
Continue reading “Inter-company loans”…

Change in use and flipping

The CRA has confirmed that a deemed disposition under subsection 45(1) of the Income Tax Act resulting from a change in use is not a disposition for the purposes of the flipping rules in subsections 12(12) and 12(13). See 2024-1027831C6.
Continue reading “Change in use and flipping”…

Swiss bank account trouble

In Azmayesh-Fard v R, 2025 TCC 20, the Court considered whether the CRA had properly reassessed a taxpayer beyond the normal reassessment period and imposed gross negligence penalties for unreported income from a Swiss bank account and for failing to…
Continue reading “Swiss bank account trouble”…

Price adjustment clause

An accounting colleague has reported to me on a CRA audit involving a price adjustment clause. The CRA challenged the valuation used for a transfer of property. The taxpayer and the CRA eventually agreed on a valuation that was about…
Continue reading “Price adjustment clause”…

Recent Posts

Guest post on the DTC

The following article on the disability tax credit was written by Tanya O’Connell, a former law clerk at Loukidelis Professional Corporation. The Disability Tax Credit (DTC) The DTC is a personal tax credit available under section 118.3 of the Income…
Continue reading “Guest post on the DTC”…

Inter-company loans

Subsection 15(1) of the Income Tax Act could apply where Aco loans money to Bco and Bco has no means of repaying the money. On the other hand, subsection 246(1) will not apply where Bco and its shareholder have no…
Continue reading “Inter-company loans”…

Change in use and flipping

The CRA has confirmed that a deemed disposition under subsection 45(1) of the Income Tax Act resulting from a change in use is not a disposition for the purposes of the flipping rules in subsections 12(12) and 12(13). See 2024-1027831C6.
Continue reading “Change in use and flipping”…

Swiss bank account trouble

In Azmayesh-Fard v R, 2025 TCC 20, the Court considered whether the CRA had properly reassessed a taxpayer beyond the normal reassessment period and imposed gross negligence penalties for unreported income from a Swiss bank account and for failing to…
Continue reading “Swiss bank account trouble”…

Price adjustment clause

An accounting colleague has reported to me on a CRA audit involving a price adjustment clause. The CRA challenged the valuation used for a transfer of property. The taxpayer and the CRA eventually agreed on a valuation that was about…
Continue reading “Price adjustment clause”…

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Archives

Categories

Recent Posts

Guest post on the DTC

The following article on the disability tax credit was written by Tanya O’Connell, a former law clerk at Loukidelis Professional Corporation. The Disability Tax Credit (DTC) The DTC is a personal tax credit available under section 118.3 of the Income…
Continue reading “Guest post on the DTC”…

Inter-company loans

Subsection 15(1) of the Income Tax Act could apply where Aco loans money to Bco and Bco has no means of repaying the money. On the other hand, subsection 246(1) will not apply where Bco and its shareholder have no…
Continue reading “Inter-company loans”…

Change in use and flipping

The CRA has confirmed that a deemed disposition under subsection 45(1) of the Income Tax Act resulting from a change in use is not a disposition for the purposes of the flipping rules in subsections 12(12) and 12(13). See 2024-1027831C6.
Continue reading “Change in use and flipping”…

Swiss bank account trouble

In Azmayesh-Fard v R, 2025 TCC 20, the Court considered whether the CRA had properly reassessed a taxpayer beyond the normal reassessment period and imposed gross negligence penalties for unreported income from a Swiss bank account and for failing to…
Continue reading “Swiss bank account trouble”…

Price adjustment clause

An accounting colleague has reported to me on a CRA audit involving a price adjustment clause. The CRA challenged the valuation used for a transfer of property. The taxpayer and the CRA eventually agreed on a valuation that was about…
Continue reading “Price adjustment clause”…

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