Monthly Archives: November 2008

Ways and Means '08

“Government of Canada Moves Quickly on Seniors’ Tax Relief and Other Outstanding Measures“. But can the government act quickly enough?

Posted in Legislation | Leave a comment

EBay released

eBay Canada Ltd. v. Canada (National Revenue), 2008 FCA 348 is now available on CanLII. The Court held that information on servers in the U.S. is not foreign-based information.

Posted in Cases, International | 1 Comment

Non-competes, again

Thursday last I tried, once again, to explain the restrictive covenant rules in proposed section 56.4 of the Income Tax Act (Canada) to a seminar hosted by the Hamilton Law Association (please send an email to me if you would … Continue reading

Posted in Miscellaneous | 2 Comments

Dividends and Section 160

Assume that Corp X owes tax to the CRA. Assume that, while it owes that tax, Corp X pays a dividend to Mr. X who deals not at arm’s length with the corporation. What can the CRA do about it … Continue reading

Posted in Corporations, Individuals | Leave a comment

Procedure

In Corsi v. The Queen, 2008 TCC 472, the CRA sent a 160 assessment to the taxpayer by registered mail in June, 2004, to her home address, which was not the address the CRA had on file for the taxpayer. … Continue reading

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

Mutual fund tax bomb?

Someone forwarded to me an email from a local accountant who was warning his clients who own mutual funds about large capital gains distributions that funds will be required to make at the end of this year because of record … Continue reading

Posted in Individuals | 2 Comments

Michigan taxes

Michael Van Severen, who is a member of the cross-border tax services group at KPMG in Hamilton, was kind enough to forward to me a “Tax Tip-Off” (I thought it said “Tax Rip-Off” when I first received it). The tip … Continue reading

Posted in International | Leave a comment