116 – Loukidelis PC

Deposit forfeited to non-resident vendor

From Georgina Tollstam, “Deposit Forfeited to Non-Resident” Canadian Tax Highlights 23:6 (June 2015): An internal technical interpretation (2013-0479861I7, March 16, 2015) confirms that if a Canadian taxpayer purchases real property located in Canada from a non-resident vendor and the sales…

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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…

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Source of income and the normal reassessment period

In Boles v R, 2024 TCC 167, the taxpayers incurred losses in respect of “Dog Activities” (breeding and selling purebred dogs and attending dog shows) and some rental properties. The Court concluded the CRA could not reassess statute-barred years for…

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Shareholder loan account entries

The taxpayer in Gabriel v R, 2024 TCC 166, seems to have had a lucky escape. He was a shareholder of a corporation that did not have its own bank account. Along with another minority shareholder, he paid expenses on…

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Adventures in trade

In Rudolph v R, 2024 TCC 148, the Court determined that gains and losses realized by the taxpayer on the sale of shares and the expiry of related options were on income account. The Court noted, among other things, that…

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Harvard Properties

In Harvard Properties Inc. v R, 2024 TCC 139, the taxpayer, as a co-owner of a shopping mall, rolled its interest in the mall to Newco and then sold the Newco shares for a “premium” over the value of the…

Continue reading…

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…

Source of income and the normal reassessment period

In Boles v R, 2024 TCC 167, the taxpayers incurred losses in respect of “Dog Activities” (breeding and selling purebred dogs and attending dog shows) and some rental properties. The Court concluded the CRA could not reassess statute-barred years for…

Continue reading…

Shareholder loan account entries

The taxpayer in Gabriel v R, 2024 TCC 166, seems to have had a lucky escape. He was a shareholder of a corporation that did not have its own bank account. Along with another minority shareholder, he paid expenses on…

Continue reading…

Adventures in trade

In Rudolph v R, 2024 TCC 148, the Court determined that gains and losses realized by the taxpayer on the sale of shares and the expiry of related options were on income account. The Court noted, among other things, that…

Continue reading…

Harvard Properties

In Harvard Properties Inc. v R, 2024 TCC 139, the taxpayer, as a co-owner of a shopping mall, rolled its interest in the mall to Newco and then sold the Newco shares for a “premium” over the value of the…

Continue reading…

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…

Source of income and the normal reassessment period

In Boles v R, 2024 TCC 167, the taxpayers incurred losses in respect of “Dog Activities” (breeding and selling purebred dogs and attending dog shows) and some rental properties. The Court concluded the CRA could not reassess statute-barred years for…

Continue reading…

Shareholder loan account entries

The taxpayer in Gabriel v R, 2024 TCC 166, seems to have had a lucky escape. He was a shareholder of a corporation that did not have its own bank account. Along with another minority shareholder, he paid expenses on…

Continue reading…

Adventures in trade

In Rudolph v R, 2024 TCC 148, the Court determined that gains and losses realized by the taxpayer on the sale of shares and the expiry of related options were on income account. The Court noted, among other things, that…

Continue reading…

Harvard Properties

In Harvard Properties Inc. v R, 2024 TCC 139, the taxpayer, as a co-owner of a shopping mall, rolled its interest in the mall to Newco and then sold the Newco shares for a “premium” over the value of the…

Continue reading…