• 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: Attribution

Attribution in action

Posted on: June 5, 2024 Last updated on: June 5, 2024 Written by: John Loukidelis
Suppose that A and B are spouses, that they purchase a cottage together for $400,000 and that A contributes $100,000 toward the satisfaction of that purchase price. The balance is financed, with A and B paying the principal and interest…
Continue reading “Attribution in action”…

Corporate attribution tips

Posted on: May 11, 2022 Last updated on: May 4, 2022 Written by: John Loukidelis
The authors summarize some methods for avoiding or mitigating corporate attribution: The corporate attribution rules do not apply where the transferee is a small business corporation. The transferor could consider effecting a freeze using a stock dividend. (But will the…
Continue reading “Corporate attribution tips”…

Prescribed rate loan

Posted on: November 14, 2020 Last updated on: November 14, 2020 Written by: John Loukidelis
In response to question 11 at the 2020 Canadian Tax Foundation Roundtable, the CRA said that a prescribed rate loan could be refinanced at a lower rate by selling property acquired with the first loan, repay the first loan and…
Continue reading “Prescribed rate loan”…

Corporate attribution

Posted on: July 9, 2018 Last updated on: November 14, 2020 Written by: John Loukidelis
Manu Kakkar, Alex Ghani and Boris Volvofsky, in “Corporate Attribution: Refreeze May Cause Unsolvable Corporate Attribution Problem” 18:3 Tax for the Owner-Manager (July, 2018), argue that a refreeze at a lower value does not reduce the outstanding amount for the…
Continue reading “Corporate attribution”…

Clever planning

Posted on: July 26, 2017 Last updated on: July 26, 2017 Written by: John Loukidelis

The Tax Court continues to be unimpressed by clever planning. Brian Arnold thinks that the current generation of tax judges is much more willing to apply the GAAR or other anti-avoidance rules to planning that reduces tax. Mady v R, 2017 TCC 112, is another case that supports his thesis.

Continue reading “Clever planning”…

Archives

Categories

Recent notes

Canada Child Benefit and Shared Custody

In Wong v R, 2025 TCC 24 (informal procedure), Mr Justice Bocock provided a helpful road map of the surprisingly complicated rules relating to shared custody and entitlement to the Canada Child Benefit.
Continue reading “Canada Child Benefit and Shared Custody”…

Misdirected assessment

Poor Mr Lam trusted his tenant to forward important mail while Mr Lam was out of the country, but the tenant left a 2016 HST assessment in a pile of junk mail. Mr Lam didn’t become aware of the assessment…
Continue reading “Misdirected assessment”…

50-50 shareholders and s 160; directors and independent contractors

McCague v R, 2025 TCC 59, is another section 160 case where 50/50 shareholders caused their corporation to pay them dividends at a time when it owed taxes. The Court held that section 160 applied and summarized the law in…
Continue reading “50-50 shareholders and s 160; directors and independent contractors”…

Preliminary vs preparatory expenses

In Lienaux v R, 2025 TCC 67 (informal procedure), the Court referred to Vesuna v R, 2022 FCA 58, and Gartry v R, 1994 CanLII 19352 (TCC), in denying expenses incurred where the taxpayer had not actually started to carry…
Continue reading “Preliminary vs preparatory expenses”…

Negligence for not reviewing return

In 994552 N.W.T. Ltd. v R, 2025 TCC 55, Mr Justice Bocock considered whether the taxpayer corporation was liable to be reassessed beyond the normal reassessment period for two taxation years and for gross negligence penalties for overclaimed capital cost…
Continue reading “Negligence for not reviewing return”…

Recent Posts

Canada Child Benefit and Shared Custody

In Wong v R, 2025 TCC 24 (informal procedure), Mr Justice Bocock provided a helpful road map of the surprisingly complicated rules relating to shared custody and entitlement to the Canada Child Benefit.
Continue reading “Canada Child Benefit and Shared Custody”…

Misdirected assessment

Poor Mr Lam trusted his tenant to forward important mail while Mr Lam was out of the country, but the tenant left a 2016 HST assessment in a pile of junk mail. Mr Lam didn’t become aware of the assessment…
Continue reading “Misdirected assessment”…

50-50 shareholders and s 160; directors and independent contractors

McCague v R, 2025 TCC 59, is another section 160 case where 50/50 shareholders caused their corporation to pay them dividends at a time when it owed taxes. The Court held that section 160 applied and summarized the law in…
Continue reading “50-50 shareholders and s 160; directors and independent contractors”…

Preliminary vs preparatory expenses

In Lienaux v R, 2025 TCC 67 (informal procedure), the Court referred to Vesuna v R, 2022 FCA 58, and Gartry v R, 1994 CanLII 19352 (TCC), in denying expenses incurred where the taxpayer had not actually started to carry…
Continue reading “Preliminary vs preparatory expenses”…

Negligence for not reviewing return

In 994552 N.W.T. Ltd. v R, 2025 TCC 55, Mr Justice Bocock considered whether the taxpayer corporation was liable to be reassessed beyond the normal reassessment period for two taxation years and for gross negligence penalties for overclaimed capital cost…
Continue reading “Negligence for not reviewing return”…

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

Canada Child Benefit and Shared Custody

In Wong v R, 2025 TCC 24 (informal procedure), Mr Justice Bocock provided a helpful road map of the surprisingly complicated rules relating to shared custody and entitlement to the Canada Child Benefit.
Continue reading “Canada Child Benefit and Shared Custody”…

Misdirected assessment

Poor Mr Lam trusted his tenant to forward important mail while Mr Lam was out of the country, but the tenant left a 2016 HST assessment in a pile of junk mail. Mr Lam didn’t become aware of the assessment…
Continue reading “Misdirected assessment”…

50-50 shareholders and s 160; directors and independent contractors

McCague v R, 2025 TCC 59, is another section 160 case where 50/50 shareholders caused their corporation to pay them dividends at a time when it owed taxes. The Court held that section 160 applied and summarized the law in…
Continue reading “50-50 shareholders and s 160; directors and independent contractors”…

Preliminary vs preparatory expenses

In Lienaux v R, 2025 TCC 67 (informal procedure), the Court referred to Vesuna v R, 2022 FCA 58, and Gartry v R, 1994 CanLII 19352 (TCC), in denying expenses incurred where the taxpayer had not actually started to carry…
Continue reading “Preliminary vs preparatory expenses”…

Negligence for not reviewing return

In 994552 N.W.T. Ltd. v R, 2025 TCC 55, Mr Justice Bocock considered whether the taxpayer corporation was liable to be reassessed beyond the normal reassessment period for two taxation years and for gross negligence penalties for overclaimed capital cost…
Continue reading “Negligence for not reviewing return”…

© Loukidelis Professional Corporation