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Category: Miscellaneous

Post Number 1,000

Posted on: November 27, 2023 Last updated on: November 27, 2023 Written by: John Loukidelis
This post is number 1,000 in this, my blog about Canadian income tax law. I have been writing here more or less regularly, since August, 2005. I started writing the blog as a way of informing clients about recent developments…
Continue reading “Post Number 1,000”…

UHT Traps

Posted on: November 10, 2022 Last updated on: November 7, 2022 Written by: John Loukidelis
It appears that the underused housing tax (UHT) might apply to residential property owned by a partnership one of the partners of which is another partnership a trust where one or more of the beneficiaries of the trust is another…
Continue reading “UHT Traps”…

Underused Housing Tax Act

Posted on: May 4, 2022 Last updated on: May 4, 2022 Written by: John Loukidelis
Bill C-8 will enact the Underused Housing Tax Act (the “UHT Act”). The UHT Act will impose an annual tax equal to 1% of the value of certain residential properties. There are steep penalties for failing to file the associated…
Continue reading “Underused Housing Tax Act”…

Betrayed by fonts

Posted on: February 2, 2022 Last updated on: February 2, 2022 Written by: John Loukidelis
This story warmed my font-nerd heart. A bankruptcy trustee hired an expert in typography and design who testified that a document supposedly created in 1995 used fonts that weren’t available to the public until 2007. *Sad trombone sound*.
Continue reading “Betrayed by fonts”…

We have moved!

Posted on: August 5, 2020 Last updated on: December 10, 2020 Written by: John Loukidelis
We have moved! We are still at 20 Hughson St S in Hamilton, but our new suite number is 707. All of our other contact details remain the same. Our updated contact information can be found here. Because of COVID-19,…
Continue reading “We have moved!”…

COVID-19 update

Posted on: July 3, 2020 Last updated on: October 2, 2020 Written by: John Loukidelis
Our office remains closed for now even as the province re-opens after the pandemic. We continue to serve our clients, however, by phone and by email. Our contact information can be found here.
Continue reading “COVID-19 update”…

Hiatus

Posted on: June 29, 2020 Last updated on: October 2, 2020 Written by: John Loukidelis
I haven’t posted since May 20, 2020, which represents one of the longest (if not the longest) stretches I’ve gone without adding content to this site. My site was hacked, and so it has taken me a while a to…
Continue reading “Hiatus”…

OFFICE CLOSED

Posted on: March 16, 2020 Last updated on: July 3, 2020 Written by: John Loukidelis
In view of the fast-developing COVID-19 pandemic, our office will be closed to the public until further notice. We remain available to assist clients via phone, email and video conference.
Continue reading “OFFICE CLOSED”…

SCC on judicial review

Posted on: March 2, 2020 Last updated on: March 2, 2020 Written by: John Loukidelis
Gergely Hegedus, “SCC on Standards of Judicial Review” (February 2020) 10:1 Canadian Tax Focus, draws the following lessons from Canada (Minister of Citizenship and Immigration) v Vavilov, 2019 SCC 65, Bell Canada v Canada (Attorney General), 2019 SCC 66, and…
Continue reading “SCC on judicial review”…

Real property registry

Posted on: August 5, 2017 Last updated on: August 5, 2017 Written by: John Loukidelis
I have written a brief article on the new-ish OBCA requirement to keep a register of interests in real property.
Continue reading “Real property registry”…
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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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