The CRA’s news releases sometimes read like a reminder from your mother to brush your teeth every day. The latest release reminds taxpayers that “the income you earn online is taxable.” But the CRA is a scary mom, the kind who will chase you around the house with a rolling pin if you are insufficiently attentive to her requirements. The release, rather ominously, admonishes taxpayers to “come to us before we come to you”.
As readers of this blog know, the Ontario Business Corporations Act was amended late last year to provide that
The articles [of a Corporation] may provide that two or more classes of shares or two or more series within a class of shares may have the same rights, privileges, restrictions and conditions.
Robin MacKnight, writing in the Canadian Tax Foundation’s Tax for the Owner-Manager in July, pointed out that:
At the 2007 STEP National Conference, the CRA was asked how it would interpret this change in the context of the attribution and income-splitting rules. Not surprisingly, its response was that tax consequences depend on more than just a name, and it would not necessarily recognize a distinction between classes of shares on that basis alone.
At some point, I will write a longer piece on requirements to pay, but for now I will rest content with pointing to Encan Construction Ltd v. The Queen, 2007 TCC 579, as an example of the heavy burden they can impose on a taxpayer. (more…)
In its latest decision on the subject of registered charities, the Supreme Court has denied the appeal of the charity in A.Y.S.A. Amateur Youth Soccer Association v. Canada (Revenue Agency), 2007 SCC 42.
Yesterday, Finance released draft legislation for the new registered disability savings plans.
The Toronto Star is reporting that the CRA has reassessed or will reassess more than 100,000 taxpayers for about $1.4 billion in taxes, interest and penalties because they participated in donation tax shelters. I posted previously about another story in the Star about a small Greek Orthodox church that was involved in one of these shelters.
