Trust accounts

Posted by John Loukidelis on January 9th, 2010

In Canada Trustco Mortgage Company v. The Queen, 2008 TCC 482, aff’d 2009 FCA 267, the Tax Court held that a financial institution must comply with a requirement to pay even where the the funds sought to be seized from the institution were held in a lawyer’s trust account. Read the rest of this entry »

Audit headlines

Posted by John Loukidelis on December 14th, 2009

It’s not often that a CRA audit makes headlines: Canada Revenue probe focuses on some RBC DS clients.

Retail Loses Again

Posted by John Loukidelis on November 26th, 2009

Taxpayers who participated in ‘retail’ donation tax shelters continue to fare poorly in the Tax Court. See MarĂ©chaux v. The Queen, 2009 TCC 587. Read the rest of this entry »

Triangles

Posted by John Loukidelis on November 18th, 2009

Don’t forget the triangular amalgamation. While these types of amalgamations are more typical in the public company context, they can be a useful tool for private company deals too. Read the rest of this entry »

Eligible Dividends

Posted by John Loukidelis on November 13th, 2009

Last week, I gave a presentation for the Hamilton Law Association on eligible dividends at its annual Corporate Commercial update. You can find a copy of a sample resolution for eligible dividends here. Use at your own risk!

Zapper

Posted by John Loukidelis on November 9th, 2009

The CRA is attempting to hunt down store owners who install software that “suppresses” records of cash sales made through a cash register. Maybe that’s an argument for making a voluntary disclosure now. Visit the taxman before he visits you.

Tax for Trusts

Posted by John Loukidelis on October 30th, 2009

The following article will appear in an upcoming  edition of the Hamilton Law Association Law Journal. Read the rest of this entry »

Freeze Shares

Posted by John Loukidelis on October 26th, 2009

The following article appeared in the latest edition of the Hamilton Law Association Law Journal. Read the rest of this entry »

Records

Posted by John Loukidelis on October 17th, 2009

The latest edition of Taylor Leibow’s Business Matters has an interesting article about record-keeping and the preparation of death returns. The article points out that poor record-keeping can be problematic in a tax system that expects taxpayers to prove they are entitled to claim deductions or what have you. In fact, a significant number of the disputes we help clients with have their origin in missing or inaccurate records.

Valuation redux

Posted by John Loukidelis on October 8th, 2009

In a post I wrote about a year ago, I complained about the CRA’s then-recent pronouncements on control premiums. The CRA, at the most recent Canadian Tax Foundation BC Conference, recanted this position, at least in part, as follows: Read the rest of this entry »


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