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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
Posted in Cases, Individuals
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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
Posted in Cases, Collections, Individuals, International
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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.
Posted in Corporations, Individuals
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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.”
Posted in CRA News, Individuals
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Voluntary Disclosures
I’ve just published a permanent page to my blog on voluntary disclosures.
Posted in CRA News, Evasion, Individuals
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Bad assets
You need to purify a corporation of its bad assets so that the corporation’s shares will be qualified small business corporation shares for the purposes of the $750,000 capital gains exemption. Let’s assume that you are confident about the values … Continue reading
Posted in Corporations, Individuals
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Form of notice
In Suffolk v. The Queen, 2010 TCC 295 (an informal procedure case), the Court undertook an interesting review of the caselaw relating to the validity of notices of assessment that contain errors and the form required for a valid notice … Continue reading
Posted in CRA News, Individuals
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White collar revisited
A few months ago, I wrote a post complaining about how the CRA tends to go after the taxpayers who get the caught in the middle of tax schemes rather than the schemers themselves. Karen Cooper has written an interesting … Continue reading
Retiring allowance exception
In Rae v. The Queen, 2010 TCC 130, the taxpayer left his position as the controller of one corporation and joined another. Soon after he started his new employment, he discovered what he thought were serious improprieties in the financial … Continue reading
Posted in Cases, Individuals
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Proceeds of Crime
The following article appeared in a recent edition of the Hamilton Law Association Law Journal. The police execute a search at your client’s house. They find pot plants and a large amount of cash. They seize the cash and charge … Continue reading
Posted in Evasion, Individuals, Policy
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