Monthly Archives: August 2007

Anchor Pointe allowed

Posted on August 23, 2007 by John Loukidelis

The Federal Court of Appeal, in The Queen v. Anchor Pointe Energy Ltd., 2007 FCA 188, has reversed Chief Justice Bowman’s decision in 2006 TCC 424. I discuss the latter decision here.

Posted in Cases, Objections, Tax Court Appeals | Leave a comment

Section 84.1

Posted on August 20, 2007 by John Loukidelis

The following article on section 84.1 of the Income Tax Act (Canada) appeared in the latest edition of the Hamilton Law Association Law Journal. 1 Accountants will tell you that mistakes involving section 84.1 of the Income Tax Act (Canada) … Continue reading →

Posted in Corporations, Individuals | Leave a comment

Warnings

Posted on August 20, 2007 by John Loukidelis

Those who have had the misfortune to participate in tax shelters gone wrong some times complain that the CRA did not do enough to warn the public about the pitfalls associated with them. The CRA appears to be trying to … Continue reading →

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The Long Arm of Section 160

Posted on August 6, 2007 by John Loukidelis

Section 160 of the Income Tax Act permits the CRA to assess “at any time” a taxpayer who receives property for inadequate consideration from a non-arm’s length person who, at the time of the transfer, has a liability under that … Continue reading →

Posted in Cases, Individuals | Leave a comment