Monthly Archives: April 2007

Trouble for a charity

I reported on a tax case involving All Saints Greek Orthodox Church here. Now the Toronto Star is reporting that the church issued receipts with a total value of about $273 million as part of the program under audit in … Continue reading

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Get help!

Beth DeMerchant, formerly of Torys LLP, testified earlier this week about her role in not making public non-compete fees paid to Lord Black (among others) in 2000. She is quoted in this morning’s National Post saying [We] violated the most … Continue reading

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Testamentary Trusts

The following article on testamentary trusts appeared in the latest edition of the Hamilton Law Association Law Journal.

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Schemes

As readers of this newsletter well know, the clear message from the courts lately has been “Woe unto you taxpayers who participate in retail tax shelters or other tax-driven schemes!” The Federal Court of Appeal has reiterated that message in … Continue reading

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ABILs

To claim an allowable business investment loss (an ABIL) in respect of an amount loaned to a corporation, a taxpayer must establish (among other things) that the amount has become a bad debt. Kyriazakos v. The Queen, 2007 TCC 66, … Continue reading

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Complexity

I couldn’t help snickering a little at the following news release: The Minister of National Revenue announced the Canada Revenue Agency’s Action Task Force on Small Business Issues Report: Helping Small Businesses by Reducing the Compliance Burden But of course … Continue reading

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Price adjustments

In Desormiers c. Lalumière, 2006 QCCS 2357, a son purchased shares from his mother and father for $500,000. The purchase and sale agreement stated that the purchase price was subject to adjustment: if the Minister of National Revenue determined that … Continue reading

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National Charity Law Symposium

I will be speaking about split receipts at the National Charity Law Symposium on May 10, 2007, in Toronto. I hope to see some of you there.

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Eligible dividends

Joe and I prepared a presentation for some area accountants on the new eligible dividend rules. You can download a copy here.

Posted in Corporations, Individuals | Leave a comment