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Monthly Archives: April 2009
Reorgs
Despite the many technical pitfalls in the reorganization provisions of the Income Tax Act, cases involving those provisions do not often come before the Tax Court. Husky Oil Limited v. The Queen, 2009 TCC 118, is one such case that … Continue reading
Posted in Corporations
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Capital dividends and 160
The Tax Court, in Neumann v. The Queen, 2009 TCC 81, has decided that a capital dividend is a transfer of property for the purposes of section 160, just like an ordinary dividend.
Posted in Cases, Corporations, Individuals
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Capital Dividends Again
The following article appeared in the latest edition of the Hamilton Law Association Law Journal.
Posted in Corporations, Individuals
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Corrupt
No doubt some taxpayers believe that the CRA is corrupt, but the truth is that most CRA personnel are dedicated and professional civil servants. On the other hand, it’s not necessarily lily-white either.
Nerd update
In the interests of doing my part to be part of Web 2.0, I’ve deleted my page on this blog devoted to links of interest to tax practitioners, and I’ve created a page of links at delicious.com instead. Those of … Continue reading
Posted in Miscellaneous
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Tax Nerd
Paragraph 149.1(4)(c) in my version of the Practitioner’s Income Tax Act (35th edition) is missing an “or” at the end of it. I emailed David Sherman, the PITA editor, about this, and he confirmed that the “or” was missing in … Continue reading
Posted in Legislation
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