Category Archives: Individuals

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.

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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

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Acting in concert

Two unrelated individuals each own 50% of a corporation. If the daughter of one of them is an employee of the corporation, does she deal with it at arm’s length for the purposes of subsection 5(2) of the Employment Insurance … Continue reading

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PC Employment Agreement

It is our standard practice when incorporating a professional corporation (a PC) to prepare an employment contract between the professional and the PC.

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160 and Knowledge

For the purposes of section 160 of the Income Tax Act, it does not matter whether the transferor or transferee knows that the transferor owes tax at the time of the transfer. What they intend to accomplish by making the … Continue reading

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Measuring Employment Benefits

If you teach at a private school, and the school offers your children discounted tuition as part of your compensation package, what is the value of the benefit that must be included in your income for the purposes of the … Continue reading

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Gifts and Family Law

When the patriarch or matriarch of a family decides to implement a freeze it is quite common for him or her to insist that the gift of the growth shares be excluded from net family property for the purposes of … Continue reading

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Buckingham

For those of us who defend director liability cases, R v Buckingham, 2011 FCA 142, is a must-read.

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T1 Short

A friend of mine was going through his father’s papers and found some old tax returns. He passed one along to me—a 1948 T1 Short—with his permission to post it here, which I am doing with names and addresses redacted. … Continue reading

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Kiddie tax

In Jeannotte v R, 2011 TCC 247, the taxpayer’s representative tried to argue that the Court should make an exception to the kiddie tax rules on income from a trust that was set up, not to avoid tax, but to … Continue reading

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