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Category: 9

Adventures in trade

Posted on: February 4, 2025 Last updated on: January 30, 2025 Written by: John Loukidelis
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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Sale of shares on income account

Posted on: December 19, 2024 Last updated on: December 19, 2024 Written by: John Loukidelis
In Rudolph v R, 2024 TCC 148, the Tax Court held that the taxpayer had not disposed of shares in 2007 as alleged by the CRA. Instead, the taxpayer had received a loan from the purchaser in 2007 that was…
Continue reading “Sale of shares on income account”…

Scams and tax

Posted on: January 10, 2024 Last updated on: January 10, 2024 Written by: John Loukidelis
In an email spoofing attack, an employee of a business might share important financial information with, or send money to a, a fraudster because the employee has received an email from the fraudster masquerading as the employee’s boss. In a…
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Stock options issued to a corporation

Posted on: September 23, 2022 Last updated on: September 23, 2022 Written by: John Loukidelis
Section 7 of the Income Tax Act (Canada) does not apply to stock options granted to a CCPC for consulting services rendered. Instead, “general tax principles” apply to determine when the CCPC must include an amount in income in respect…
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Happy Valley applied

Posted on: October 27, 2021 Last updated on: October 27, 2021 Written by: John Loukidelis
Happy Valley Farms Ltd. v MNR, 2 CTC 259, provides a handy list of the factors a court will generally consider in deciding whether a gain realized on the sale of a home was on income account. The Court…
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Inventory adjustment disallowed

Posted on: April 12, 2021 Last updated on: April 16, 2021 Written by: John Loukidelis
In Yorkwest Plumbing Supply Inc. v R, 2020 TCC 122, the Court considered an adjustment of $1.2 million that the taxpayer had made to its 2012 net income in respect of inventory that had been purchased and sold before the…
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TIP case

Posted on: April 12, 2021 Last updated on: April 16, 2021 Written by: John Loukidelis
Motter c Agence du revenue du Québec, 2021 QCCA 72, aff’g 2018 QCCQ 3483, found that tenant inducement payments “are not an expense category for the purpose of calculating income from a business or property, nor are they a subcategory…
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Bitcoin mining

Posted on: August 29, 2019 Last updated on: August 29, 2019 Written by: John Loukidelis
The CRA, in technical interpretation 2018-0776661I7 (August 8, 2019), takes the position that a Bitcoin miner receives Bitcoin as barter for services rendered. The transaction is a barter transaction because Bitcoin isn’t legal tender (see IT-490 “Barter Transactions”). The receipt…
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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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