Monthly Archives: August 2006

Rectification again

Posted on August 29, 2006 by John Loukidelis

The Ontario Reports just published another rectification case. See Di Battista v. 874687 Ontario Inc., 80 O.R. (3d) 136, 2005 CanLII 51220 (ON S.C.). The report is sketchy on the details, but it contains a useful list of the relevant … Continue reading →

Posted in Cases | Leave a comment

Intention and dance

Posted on August 26, 2006 by John Loukidelis

Sometimes my clients like to tell me that “in tax, intention is everything”. In fact, the courts have always been quite careful to limit the role that mere subjective intention plays in determining the tax consequences of a transaction. For … Continue reading →

Posted in Cases | Leave a comment

CRA "Service"

Posted on August 24, 2006 by John Loukidelis

I am back from holidays now and back to having to deal with the many-headed Hydra that is the CRA. Over the last few years the CRA has been “rationalizing” its services to cut costs and, supposedly, improve its services. … Continue reading →

Posted in CRA News | Leave a comment

PCs and Personal Service Businesses

Posted on August 4, 2006 by John Loukidelis

Under the Income Tax Act (Canada) (the “Act”) significant tax advantages may be available to a professional who derives his or her income through a corporation, of which he or she is both a shareholder and an employee, rather than … Continue reading →

Posted in Individuals | Leave a comment