• Skip to main navigation
  • Skip to main content
  • Skip to footer
Loukidelis PC

Loukidelis PC

Effective. Accessible. Responsive

  • Services
  • Team
  • LPC Notes
  • Articles
  • Privacy Policy
  • Contact Us
  • Disclaimer
  • Skip to menu toggle button

Category: Bad debts and ABILs

Form matters for an ABIL

Posted on: April 23, 2022 Last updated on: April 21, 2022 Written by: John Loukidelis
In Dias v R, 2021 TCC 85, the taxpayers unsuccessfully argued that loans that appeared to be to a numbered company had actually been made to corporations that might have been small business corporations (the numbered company was not). The…
Continue reading “Form matters for an ABIL”…

ABIL denied

Posted on: November 27, 2019 Last updated on: November 27, 2019 Written by: John Loukidelis
In Moose Factory Restaurant Properties Ltd. v R, 2019 TCC 156, the taxpayer claimed an ABIL in respect of a debt of a third party that the taxpayer had guaranteed. The third party went bankrupt leaving the taxpayer exposed under…
Continue reading “ABIL denied”…

Ponzi schemes and bad debts

Posted on: April 15, 2019 Last updated on: April 15, 2019 Written by: John Loukidelis
Although the CRA doesn’t mention Delle Donne v R, 2015 TCC 150 (discussed here), it recently considered when a victim of a ponzi scheme can write off a bad debt in respect of interest previously included in income. See 2017-0691941I7…
Continue reading “Ponzi schemes and bad debts”…

Interest on debt to acquire land; bad debts

Posted on: September 16, 2015 Last updated on: September 16, 2015 Written by: John Loukidelis
Per Lyons J in Kokai-Kuun Estate v R, 2015 TCC 217: a taxpayer cannot add to the cost of vacant land interest and property taxes paid in respect of the land where it was acquired for “investment” purposes but never…
Continue reading “Interest on debt to acquire land; bad debts”…

Delle Donne v HMQ

Posted on: July 16, 2015 Last updated on: July 16, 2015 Written by: John Loukidelis
The Financial Post has a report in it today on Delle Donne v R, 2015 TCC 150, in which yours truly acted as counsel for the taxpayer. Translation of Bill Innes’ comment in the Post article: even a chimp could…
Continue reading “Delle Donne v HMQ”…

Proposal problems for ABILs

Posted on: July 12, 2015 Last updated on: July 13, 2015 Written by: John Loukidelis
In Gaumond v R, 2014 TCC 339, an informal procedure case, the taxpayer, as part of a proposal under the Bankruptcy and Insolvency Act, forgave a debt owed to him by a CCPC he controlled. The Tax Court denied the…
Continue reading “Proposal problems for ABILs”…

Archives

Categories

Recent notes

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”…

Archives

Categories

Meta

  • Log in
  • Entries feed
  • Comments feed
  • WordPress.org

About this site

Click here for an important disclaimer about this site.

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”…

© Loukidelis Professional Corporation