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Author Archives: John Loukidelis
“Employee” loans
In Rémillard v R, 2011 TCC 327, the Court spent some time considering whether an employee is required to include an amount in income in respect of a loan advanced to him by his corporate employer if the loan is … Continue reading
Posted in Cases, Individuals
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Gambling again
Mr. Giuseppe Tarascio is not having much luck convincing the tax courts that his gambling losses should be deductible from his income for tax purposes. See Tarascio v R, 2012 FCA 30, aff’g a decision of Associate Chief Justice Rossiter … Continue reading
Posted in Cases
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Quotes
I’ve been quoted a couple of times recently in tax-related stories in The Lawyers Weekly, most recently in a story on Johnson v R, 2011 TCC 540, which I wrote about here.
Posted in Cases, Miscellaneous
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Freeze share values
Bryan Walters has drawn my attention to an interesting CRA technical interpretation (2011-0404641C6 or CCH Window ¶10,832) in which the CRA states that the provisions of a shareholder agreement might reduce the value of freeze shares that otherwise have the … Continue reading
Posted in Miscellaneous
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55(2)-land
I didn’t understand CRA technical interpretation 2011-0394191 at first, but I think I get it now.
Posted in Corporations
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Goodwill and estate planning
Mark Brohman at Durward Jones Barkwell was kind enough to send to me a reminder in the form of a technical interpretation of a very important fact about goodwill and estate planning.
Posted in Estates and Trusts, Individuals
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Corollary
In Vankerk v R, 2006 FCA 96 (which I wrote about here), the Court held that a taxpayer could not deduct a loss incurred in connection with an “investment” in a business that turned out to be a fraud. A … Continue reading
Donation tax shelter class action
For an article on donation tax shelter class actions, click here.
Tax protesters redux (ridiculous more like)
The CRA is warning Canadians to stay away from the tax protest movement, again. I can’t believe people are still falling for this crap given that, as the CRA release points out, “Canadian courts have repeatedly and consistently rejected all … Continue reading
Posted in CRA News, Individuals
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CRA News
The CRA issued a couple of interesting technical interpretations in the last few months. Foreign Entity Classification The CRA will no longer issue technical interpretations on foreign entity classification (CRA technical dated August 04, 2011, 2011-0415141E5) because whether the foreign … Continue reading
Posted in CRA News
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