Monthly Archives: June 2007

Budget bill enacted

Bill C-52 received Royal Assent on June 22. It is now law as S.C. 2007, c. 29.

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Subsection 75(2)

The following article on subsection 75(2) of the Income Tax Act (Canada) appeared in the latest edition of the Hamilton Law Association Law Journal.

Posted in Estates and Trusts, Individuals | 1 Comment

Useful links

I maintain a page on this site with some useful links for the tax practitioner. I have just added a link to the CRA’s page listing its prescribed rates. If any of you have other ideas for useful links that … Continue reading

Posted in Miscellaneous | Leave a comment

Bill C-52 takes the lead

Bill C-52, which implements “certain provisions of the budget tabled in Parliament on March 19, 2007″, is now at the “Report Stage” (the stage immediately before 3rd Reading). Meanwhile, poor old Bill C-33 continues to languish in committee. Bill C-33 … Continue reading

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Broker receiving fees through a company

In Boutilier v. The Queen, 2007 TCC 96, the taxpayer received trailer fees and reported them as income he had earned. Later, he purported to transfer his fee-earning business to a company. Fees received by the taxpayer were assigned to … Continue reading

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"Indirectly … by any other means whatever"

In St-Pierre c. La Reine, 2007 CCI 90, the taxpayer transferred shares of a corporation to his management company, which he controlled. The management company transferred the shares to the taxpayer’s spouse. The spouse later disposed of shares substituted for … Continue reading

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A Mind Bender

How do subsection 55(2) and Part IV of the Income Tax Act (Canada) work together? The Tax Court considered this question recently in Ottawa Air Cargo Centre Ltd. v. The Queen, 2007 TCC 193 (“Air Cargo”).

Posted in Cases, Corporations | Leave a comment