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Category: Corporations (page 3)

256(6) and Indemnities

Posted on: March 15, 2015 Last updated on: March 15, 2015 Written by: John Loukidelis
According to CRA technical interpretation 2015-0565741E5, subsection 256(6) will not save the CCPC status of a corporation whose shares are pledged to secure an indemnity. The CRA concluded that an indemnity is not a debt for the purposes of the…
Continue reading “256(6) and Indemnities”…

Notes on Shares of a Specified Class

Posted on: March 6, 2015 Last updated on: March 6, 2015 Written by: John Loukidelis
In applying the association rules in subsection 256(1) of the Income Tax Act (Canada), one can ignore shares of a specified class as defined in subsection 256(1.1). The CRA has said the following about that definition. Regarding the requirements in…
Continue reading “Notes on Shares of a Specified Class”…

Currency swaps

Posted on: February 25, 2015 Last updated on: February 25, 2015 Written by: John Loukidelis
Craig Burley has written a good short post on George Weston Limited v R, 2015 TCC 42, a case argued for the taxpayer by my old friend from law school days, Sal Mirandola.
Continue reading “Currency swaps”…

55(5)(f) designations are unnecessary?

Posted on: February 21, 2015 Last updated on: January 4, 2016 Written by: John Loukidelis
Neal Armstrong reports on the CRA pronouncement regarding 55(5)(f) designations at the 2014 STEP Roundtable: CRA stated that its long-standing practice “is to apply subsection 55(2) only to the excess of the taxable dividend paid on a share over the…
Continue reading “55(5)(f) designations are unnecessary?”…

MGS on strike?

Posted on: February 6, 2015 Last updated on: February 6, 2015 Written by: John Loukidelis
The following is from an OPSEU press release issued last week: The union representing 35,000 frontline Ministry employees who work directly for the Ontario government announced today that bargaining representatives of the Ontario Government have taken a significant step towards…
Continue reading “MGS on strike?”…

84.1 and employee buycos

Posted on: January 20, 2015 Last updated on: January 20, 2015 Written by: John Loukidelis
I gave a talk today at the Hamilton Law Association on shareholder agreements and tax issues. David Howell asked me a question, on which I drew a blank, relating to employee buycos. Thanks to Shelley Wickenheiser, I was able to…
Continue reading “84.1 and employee buycos”…

Deemed ownership of shares

Posted on: January 18, 2015 Last updated on: January 18, 2015 Written by: John Loukidelis
I am giving a talk on Tuesday at the Hamilton Law Association on tax issues in shareholder agreements. From my speaking notes: The language of 251(5)(b) and subsection 256(1.4) appear to be very similar, but the CRA has maintained an…
Continue reading “Deemed ownership of shares”…

New folio on amalgamations

Posted on: December 2, 2014 Last updated on: December 2, 2014 Written by: John Loukidelis
The CRA has published a new folio on amalgamations here.
Continue reading “New folio on amalgamations”…

Inter-company Management Fees

Posted on: October 26, 2014 Last updated on: October 26, 2014 Written by: John Loukidelis
A detailed services agreement was not enough by itself to justify the deduction of management fees paid by Opco to Holdco. The court wanted evidence of the services rendered, the service hours provided, the hourly rate and the identity of…
Continue reading “Inter-company Management Fees”…

Providing space

Posted on: October 20, 2014 Last updated on: October 20, 2014 Written by: John Loukidelis
Craig Burley has blogged about 0742443 BC Ltd v R, 2014 TCC 301. His takeaway on the case? “If you have a business that incorporates any sort of rental of space, or allowing customers to use your space, I recommend…
Continue reading “Providing space”…
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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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