Category Archives: Individuals

The Gambler

The upsurge in interest in all things poker-related has sort of passed me by, like a lot of other trends and fashions. But, because I am a tax nerd, I have asked myself why it is that those who make … Continue reading

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Privilege and a claim for legal expenses

In RICHARD A. KANAN CORPORATION v R, 2011 TCC 211, an informal procedure case, the Court was asked “how much information can the Minister, or the Court, require a taxpayer to produce in support of his or her expenses, if … Continue reading

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Garron leave granted

The Supreme Court of Canada has granted leave to appeal in St. Michael Trust Corp. v. The Queen, 2010 FCA 309, aff’g Garron Family Trust v. The Queen, 2009 TCC 450.

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The Savoy

Savoy v. The Queen, 2011 TCC 35, should be required reading for anyone called on to defend an individual from an assessment for unremitted source deductions.

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Resignation

The Ontario Ministry of Government Services (MGS), it appears, seems to believe that the sole director of a corporation cannot resign and leave the corporation without directors. The MGS will refuse to amend the public record for a corporation to … Continue reading

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Childcare receipts

A casual reading of subsection 63(1) of the Income Tax Act suggests that a taxpayer claiming childcare expenses is required to produce receipts from the person providing the care. The subsection seems to permit the deduction of expenses “the payment … Continue reading

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"Received"

In Morrison v. The Queen, 2010 TCC 429 (an informal procedure appeal), the individual taxpayers were employees of a corporation of which they were the controlling shareholders. The corporation purported to pay salary to the taxpayers by remitting amounts on … Continue reading

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Antle and Garron

The Federal Court of Appeal has released its reasons for dismissing the appeal of the taxpayer in Antle. See Antle v. The Queen, 2010 FCA 280. The reasons are also now available online in St. Michael Trust Corp. v. The … Continue reading

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Purity

Yesterday, I presented my paper on “Purifications” and the capital gain exemption to the Hamilton Law Association’s corporate commercial seminar.

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Some Big Numbers on Charity Tax Shelters

Today’s Globe and Mail reports that the CRA has reassessed, or soon will reassess, up to 170,000 Canadians “who have allegedly claimed $5-billion in bogus charitable donations since 2003 by using controversial tax shelter programs.”

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