Monthly Archives: January 2007

Damage control

The Minister of Finance tries to explain his position on income trusts and the problems created by his announcement on Halloween, 2006.

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Hammill

The Supreme Court recently refused leave to appeal to the taxpayer in Hammill v. The Queen, 2005 FCA 252. I wrote about this case here.

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Case update

On February 1, I will be speaking to the CRA practitioner’s group at the Royal Botanical Gardens about “Tax Cases of Interest”. I have written here about all of the cases on which I will present. The following table lists … Continue reading

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Salary to children

Bradley v. The Queen, 2006 TCC 500, is something of a surprise. The appellant paid salaries to her young children and attempted to deduct them. The CRA reassessed, and the Tax Court upheld the reassessment because, in the Court’s view, … Continue reading

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PC trouble

In Morisset c. La Reine, 2006 CCI 483 (French only), the CRA reassessed the taxpayer to include in his income amounts supposedly earned by his “professional corporation”. The taxpayer, at law, was not permitted to share the revenue derived from … Continue reading

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Damages again

Valley Equipment Limited v. The Queen, 2006 TCC 510, is interesting reading in light of Bourgault Industries Ltd. v. The Queen, 2006 TCC 449. In Valley Equipment, the Tax Court judge stated that there was no need to resort to … Continue reading

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Salary and shareholder loan accounts

In Irmen v. The Queen, 2006 TCC 475, the taxpayer, a shareholder and key employee of a corporation, received amounts from the corporation throughout the taxation year. During the year, the corporation accounted for the amounts as salary, and CPP … Continue reading

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Redeemer Foundation

Some time ago, I wrote a post about M.N.R. v. Redeemer Foundation, 2006 FCA 325. At the time, an online version of the judgement had not yet been published. You can now find the judgement here.

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Fraud, again

It appears that even the Department of Finance is having to wage war on phishing: see E-mail Fraud Alert.

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Eliminating tax packages

I wonder how much confusion this will create: Elimination of Tax Packages for Individuals Using the Services of a Tax Professional.

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