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Category: Miscellaneous (page 13)

Fraud, again

Posted on: January 11, 2007 Last updated on: January 11, 2007 Written by: John Loukidelis
It appears that even the Department of Finance is having to wage war on phishing: see E-mail Fraud Alert.
Continue reading “Fraud, again”…

Information for individuals leaving Canada

Posted on: January 5, 2007 Last updated on: January 5, 2007 Written by: John Loukidelis
From time to time my clients contemplate leaving Canada for warmer weather or more friendly tax collectors. Over the years, I have collected a set of CRA publications and forms that provide useful guidance on the tax consequences of becoming…
Continue reading “Information for individuals leaving Canada”…

Draft legislation for Christmas

Posted on: December 22, 2006 Last updated on: December 22, 2006 Written by: John Loukidelis
The Department of Finance generally gives tax practitioners a little something—obscure draft legislation usually—to chew on between Christmas and New Year’s. I was beginning to worry that the Department had forgotten about us this year, but I should have known…
Continue reading “Draft legislation for Christmas”…

The night before Christmas

Posted on: December 21, 2006 Last updated on: December 21, 2006 Written by: John Loukidelis

The following mentions tax, and so I think it is legitimate content for this blog.

May I say that we lawyers deserve the satire aimed at us by this poem.

Continue reading “The night before Christmas”…

New blogs

Posted on: December 16, 2006 Last updated on: December 16, 2006 Written by: John Loukidelis
Our firm is in the process of rolling out several new blogs. One of them is about trusts and estates. Cathy Olsiak and I have just posted an article to the blog about donating securities through a will.
Continue reading “New blogs”…

Ontario simplifies

Posted on: December 13, 2006 Last updated on: December 13, 2006 Written by: John Loukidelis
You have all read that the Ontario government plans to turn over the administration of its corporate income tax regime to the CRA. The government introduced draft legislation today to make that a reality. Now, when will the government muster…
Continue reading “Ontario simplifies”…

Criminal Charges

Posted on: November 16, 2006 Last updated on: November 16, 2006 Written by: John Loukidelis
It appears that over the last few years the Ontario Ministry of Finance has been getting tough with the directors of corporations who fail to file Ontario corporate tax returns. Failing to file such a return is a criminal offence,…
Continue reading “Criminal Charges”…

Learning in the Distinct Society

Posted on: November 16, 2006 Last updated on: November 16, 2006 Written by: John Loukidelis
I returned to the office today after having been away to attend the CICA‘s Advanced Tax Issues for the Owner-Managed Business course in Mont Tremblant, Quebec. The course was intense—there is such a thing as too much discussion about income…
Continue reading “Learning in the Distinct Society”…

New draft legislation

Posted on: November 9, 2006 Last updated on: November 9, 2006 Written by: John Loukidelis
Usually the Department of Finance waits until closer to Christmas to release draft legislation. Thus Finance wreaks its revenge on tax practitioners by forcing them to read its opaque, sometimes stupefying prose during the Christmas break. Christmas came early this…
Continue reading “New draft legislation”…

Income trust roller coaster

Posted on: November 1, 2006 Last updated on: November 1, 2006 Written by: John Loukidelis
You read it in the paper this morning. Now see the details of the Minister of Finance’s plan for income trusts here and hang on to your hats.
Continue reading “Income trust roller coaster”…
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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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