The latest edition of Taylor Leibow‘s Business Matters has an interesting article about record-keeping and the preparation of death returns. The article points out that poor record-keeping can be problematic in a tax system that expects taxpayers to prove they…
Lawyer joke
Every now and then I can’t resist a little legal humour. The following joke is relayed by the law blog Sui Generis:
Demand notes
Lawyers will be familiar with Hare v. Hare, 2006 CanLII 41650, in which the Ontario Court of Appeal held that the limitation period for a demand note began to run with its delivery not with default, much to the consternation…
Disposition
An employee of a corporation owns an option to purchase a share in the capital of the corporation. The corporation decides to amend the terms of the option. Does the amendment have any tax consequences? Maybe.
Tiny
I often send links to clients and colleagues by email, but sometimes the links are extremely long and complicated so that they are broken and unusable when they arrive at their destination. That’s where tinyurl.com comes in handy. “http://www.lawtimesnews.com/Headline-News/Record-$169-million-award-will-raise-the-bar” becomes…
Nerd update
In the interests of doing my part to be part of Web 2.0, I’ve deleted my page on this blog devoted to links of interest to tax practitioners, and I’ve created a page of links at delicious.com instead. Those of…
Election for Restrictive Covenants
Bryan Walters at Wade Group was kind enough to forward to me a link to the five-page “election letter” that the CRA wants taxpayers to use who are making elections under subsection 56.4(3) of the Income Tax Act.
Non-competes, again
Thursday last I tried, once again, to explain the restrictive covenant rules in proposed section 56.4 of the Income Tax Act (Canada) to a seminar hosted by the Hamilton Law Association (please send an email to me if you would like a copy of the PowerPoint presentation). I’m not sure how well I succeeded. I find the rules difficult to work with and impossible to explain because they are so full of apparently random tricks and traps.
Yubnub
I’ve found yubnub.org to be a pretty useful tool especially after I integrated it with Firefox, my browser of choice. With a few keystrokes, I am able to perform searches, including Google and Google Maps searches, without having to go to the search engine websites.
Yubnub allows a user to create custom commands, and I have created three that are tax-related.
Rectification, again
The Niagara region seems to be doing its part to contribute to the law of rectification in the tax context. Juliar v. Canada (Attorney General), 1999 CanLII 15097 (ON S.C.) originated in the peninsula. Now comes QL Hotel Service Limited v. Ontario (Finance), 2008 CanLII 15226 (ON S.C.). In the latter case, one corporation incorporated another and then transferred intangible property to the other for one common share and tangible property for one million Class A Special Shares. The transferor then sold the shares of the transferee to an arm’s length purchaser.