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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
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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
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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
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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
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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
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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
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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
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