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Author: John Loukidelis (page 102)

Children’s Fitness Tax Credit

Posted on: March 28, 2007 Last updated on: March 28, 2007 Written by: John Loukidelis
We have received a few inquiries from interested parents and athletic organizations asking for information about the new children’s fitness tax credit. The CRA has published some useful information for parents and organizations on its website.
Continue reading “Children’s Fitness Tax Credit”…

Partnership reporting changes, again

Posted on: March 27, 2007 Last updated on: March 27, 2007 Written by: John Loukidelis
David Bazar was kind enough to point out that, in fact, the CRA has delayed the implementation of the administrative change noted in my last post. Please see the CRA notice here.
Continue reading “Partnership reporting changes, again”…

Partnership reporting changes

Posted on: March 27, 2007 Last updated on: March 27, 2007 Written by: John Loukidelis

The Golden Horseshoe Tax Study Group met yesterday. Kathryn Smith pointed out to the group that the CRA has changed its administrative policy on the reporting required of a partnership.

Continue reading “Partnership reporting changes”…

Property

Posted on: March 23, 2007 Last updated on: March 23, 2007 Written by: John Loukidelis

Every now and then a taxpayer proposes to transfer an intangible “something” to a corporation for valuable consideration. The taxpayer, or his or her advisers, would do well to read Tri Pacific Gas Corporation v. Canada, 2007 FCA 38, before proceeding.

Continue reading “Property”…

Budget news

Posted on: March 19, 2007 Last updated on: March 19, 2007 Written by: John Loukidelis
The CBC has a good quick summary of the federal budget.
Continue reading “Budget news”…

CRA service update

Posted on: March 8, 2007 Last updated on: March 8, 2007 Written by: John Loukidelis
The CRA’s latest press release on its service problems can be found here.
Continue reading “CRA service update”…

Latest news on efile

Posted on: March 7, 2007 Last updated on: March 7, 2007 Written by: John Loukidelis
The CBC has the latest news on the CRA’s efile problems. The CRA has provided more detail in a “fact sheet“.
Continue reading “Latest news on efile”…

CRA suspends online service

Posted on: March 6, 2007 Last updated on: March 6, 2007 Written by: John Loukidelis
The CRA has suspended online service for individuals—including e-filing—until further notice, apparently “to safeguard existing systems and to maintain the integrity of CRA’s taxpayer information holdings”. The full news release is here.
Continue reading “CRA suspends online service”…

Voluntary disclosures in Ontario

Posted on: March 5, 2007 Last updated on: March 5, 2007 Written by: John Loukidelis
The CRA is changing the way voluntary disclosures are processed in Ontario. See its press release here.
Continue reading “Voluntary disclosures in Ontario”…

Eligible dividends

Posted on: February 27, 2007 Last updated on: February 27, 2007 Written by: John Loukidelis

Joe and I will be giving a presentation on the new eligible dividend rules on Thursday, March 1, at noon at the Hamilton Chamber of Commerce. We will provide an overview of these rather complex rules and present some planning ideas and issues to consider.

Continue reading “Eligible dividends”…
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Recent notes

The sibling butterfly exception

The CRA has clarified that the subparagraph 55(5)(e)(i) exception for siblings will apply where the shares of either the distributing corporation (DC) or the transferee corporation (TC) (not both) need be quaified small business corporation shares or shares of a…
Continue reading “The sibling butterfly exception”…

Objections for large corporations

A corporation is a “large corporation” if its taxable capital, and that of any related corporation, employed in Canada exceeds $10 million (a limit that has not changed since it was set in 2006). Per subsection 165(1.11), a large corporation…
Continue reading “Objections for large corporations”…

Pleading away privilege

In One York Street Inc. v 2360083 Ontario Limited, 2026 ONCA 176, the Court held that, by putting in issue its state of mind on signing a lease where the state of mind was based in part on legal advice,…
Continue reading “Pleading away privilege”…

Resigning as a director

According to the author, Stevens v R, 2026 TCC 76, is an important reminder of the importance of “objective” evidence for a director’s resignation. Having a resignation witnessed, ensuring that the corporation has updated its records and ensuring that the…
Continue reading “Resigning as a director”…

Build Canada announcements

Oslers has a couple of good posts on its website—here and here—about tax-related “Canada strong” announcements. The CRA, when considering advance tax rulings, will prioritize “nation-building projects”, and the Income Tax Act (Canada) will be amended to permit a new…
Continue reading “Build Canada announcements”…

Recent Posts

The sibling butterfly exception

The CRA has clarified that the subparagraph 55(5)(e)(i) exception for siblings will apply where the shares of either the distributing corporation (DC) or the transferee corporation (TC) (not both) need be quaified small business corporation shares or shares of a…
Continue reading “The sibling butterfly exception”…

Objections for large corporations

A corporation is a “large corporation” if its taxable capital, and that of any related corporation, employed in Canada exceeds $10 million (a limit that has not changed since it was set in 2006). Per subsection 165(1.11), a large corporation…
Continue reading “Objections for large corporations”…

Pleading away privilege

In One York Street Inc. v 2360083 Ontario Limited, 2026 ONCA 176, the Court held that, by putting in issue its state of mind on signing a lease where the state of mind was based in part on legal advice,…
Continue reading “Pleading away privilege”…

Resigning as a director

According to the author, Stevens v R, 2026 TCC 76, is an important reminder of the importance of “objective” evidence for a director’s resignation. Having a resignation witnessed, ensuring that the corporation has updated its records and ensuring that the…
Continue reading “Resigning as a director”…

Build Canada announcements

Oslers has a couple of good posts on its website—here and here—about tax-related “Canada strong” announcements. The CRA, when considering advance tax rulings, will prioritize “nation-building projects”, and the Income Tax Act (Canada) will be amended to permit a new…
Continue reading “Build Canada announcements”…

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Archives

Categories

Recent Posts

The sibling butterfly exception

The CRA has clarified that the subparagraph 55(5)(e)(i) exception for siblings will apply where the shares of either the distributing corporation (DC) or the transferee corporation (TC) (not both) need be quaified small business corporation shares or shares of a…
Continue reading “The sibling butterfly exception”…

Objections for large corporations

A corporation is a “large corporation” if its taxable capital, and that of any related corporation, employed in Canada exceeds $10 million (a limit that has not changed since it was set in 2006). Per subsection 165(1.11), a large corporation…
Continue reading “Objections for large corporations”…

Pleading away privilege

In One York Street Inc. v 2360083 Ontario Limited, 2026 ONCA 176, the Court held that, by putting in issue its state of mind on signing a lease where the state of mind was based in part on legal advice,…
Continue reading “Pleading away privilege”…

Resigning as a director

According to the author, Stevens v R, 2026 TCC 76, is an important reminder of the importance of “objective” evidence for a director’s resignation. Having a resignation witnessed, ensuring that the corporation has updated its records and ensuring that the…
Continue reading “Resigning as a director”…

Build Canada announcements

Oslers has a couple of good posts on its website—here and here—about tax-related “Canada strong” announcements. The CRA, when considering advance tax rulings, will prioritize “nation-building projects”, and the Income Tax Act (Canada) will be amended to permit a new…
Continue reading “Build Canada announcements”…

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