In Andre Lamy Medicine Professional Corporation v R, 2020 TCC 61 (informal), the Court considered whether a Hamilton-based professional corporation (PC) was entitled to SRED credits. Some of the contracts relating to the research underlying the claim for the credits…
New frontier
Alex Klyguine, in “Income Splitting After the New Private Corporation Proposals: Salaries Paid to Family Members” 8:1 Canadian Tax Focus (February 2018), discusses Gabco Limited v MNR, 68 DTC 5210 (Ex. Ct.)), and suggests that “the boundaries of the reasonableness test…
Discretionary dividend shares
Readers of this blog will know that I am not a fan of discretionary dividend shares (shares issued for $1, or some other nominal amount, that are redeemable for that amount but entitled to unlimited dividends). I harbour these concerns…
Tax fairness for realtors
Bill 69, the Tax Fairness for Realtors Act, 2015, received first reading in the Ontario legislative assembly on February 26, 2015. The explanatory note accompanying the Bill reads as follows: The Bill amends the Real Estate and Business Brokers Act,…
PCs for doctors: a long overdue change
The application and renewal process for certificates of status for the professional corporations (PCs) of doctors and dentists was rather labyrinthine. The College of Physicians and Surgeons recently announced that the process for doctors has been simplified. In an email it sent to subscribers to its corporate mailing list, the College summarized the changes as follows.
Inter-company Management Fees
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…
PC Income Splitting
Assume that Ms X, a lawyer in Ontario, wishes to incorporate a professional corporation (PC). Unlike her doctor and dentist clients, she can’t permit her husband to subscribe for shares in the capital of the PC because only members of…