Monthly Archives: July 2007

QSBCS Status

Posted on July 28, 2007 by John Loukidelis

Estate of Edward Reilly v. The Queen, 2007 TCC 404, considers whether shares of a corporation owned by an individual were qualified small business corporation shares (QSBCS) at the time of his death. If the shares had been QSBCS, the … Continue reading →

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Eligible Dividend Trouble

Posted on July 20, 2007 by John Loukidelis

The CRA issued a notice on July 10, which included the following paragraph about difficulties with its GRIP calculation schedule:

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Delay

Posted on July 12, 2007 by John Loukidelis

The Supreme Court released its decision today in The Queen v. Addison & Leyen Ltd., 2007 SCC 33. The case considers whether the CRA really can assess a taxpayer “at any time” under section 160 of the Income Tax Act.

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"Written agreement"

Posted on July 7, 2007 by John Loukidelis

Shaw v. The Queen, 2007 TCC 148, an informal procedure decision of the Tax Court, considered the meaning of “written agreement” as found in the provisions of the Income Tax Act governing the deductibility of support.

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GST and Damages

Posted on July 2, 2007 by John Loukidelis

Damages paid for breach of contract, either pursuant to a judgment or further to a settlement, can be subject to GST. Section 182 of the Excise Tax Act provides that any such amount is deemed to include GST, which the … Continue reading →

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