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Category: Price adjustment clauses

Price adjustment clause

Posted on: February 20, 2025 Last updated on: February 14, 2025 Written by: John Loukidelis
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…
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Price adjustment clauses per CRA

Posted on: July 29, 2017 Last updated on: July 31, 2017 Written by: John Loukidelis

The following is my summary of a presentation on price adjustment clauses (PACs) given by Nicholas Correia, CRA, to the CICBV Annual Conference, June, 2017. My comments and questions are in brackets.

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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”…

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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”…

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