Monthly Archives: December 2007

Merry Christmas

Posted on December 20, 2007 by John Loukidelis

Merry Christmas everyone, from your friends at the Department of Finance: Government of Canada Announces Technical Amendments to Clarify the Specified Investment Flow-Through Entity Tax Rules.

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Interest relief

Posted on December 18, 2007 by John Loukidelis

The late 1980′s and early 1990′s were riotous times for tax shelters and their promoters. Unfortunately, many of them tended to leave taxpayers with severe hangovers in the form of large tax bills complete with assessments for interest amounts that … Continue reading →

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Bill C-28

Posted on December 17, 2007 by John Loukidelis

Bill C-28—”an Act to implement certain provisions of the budget tabled in Parliament on March 19, 2007 and to implement certain provisions of the economic statement tabled in Parliament on October 30, 2007″—received Royal Assent on Friday. The bill became … Continue reading →

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Third parties

Posted on December 12, 2007 by John Loukidelis

One of my very first posts on this blog dealt with demands for information about third parties. The saga continues in Canada (National Revenue) v. The Greater Montréal Real Estate Board, 2006 FC 1069, in which the Court vacated its … Continue reading →

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10 Years

Posted on December 12, 2007 by John Loukidelis

In a post I wrote some time ago, I argued that the 10-year limitation rule for fairness (taxpayer relief) applications is ambiguous. I also noted that the CRA believes the rule is clear, and apparently it maintains that position still, … Continue reading →

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CRA Report

Posted on December 8, 2007 by John Loukidelis

The CRA has made its annual report to Parliament, and parts of it make for interesting reading. Essentially the report amounts to the CRA’s report card on itself. The report discusses outstanding tax debts among other things. The report notes … Continue reading →

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Income-splitting gone wrong

Posted on December 8, 2007 by John Loukidelis

In Demers c. La Reine, 2006 CCI 504, the taxpayer tried to split income with his minor daughters. The Court ruled against the taxpayer, in part because it considered artificial the payment of thousands of dollars of dividends on shares … Continue reading →

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C-10

Posted on December 6, 2007 by John Loukidelis

Bill C-10 has received second reading in the Senate and has been referred to committee.

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