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Author: John Loukidelis (page 13)

Foreignco owning a vacation property

Posted on: December 2, 2023 Last updated on: November 27, 2023 Written by: John Loukidelis
The CRA confirmed that a non-resident corporation that owns a Canadian vacation property confers a benefit on its non-resident shareholders where the shareholders or non-arm’s length persons use the property. The benefit, as a deemed dividend (214(3)(a)), is subject to…
Continue reading “Foreignco owning a vacation property”…

Deduction for TOSI under 20(1)(ww)

Posted on: December 1, 2023 Last updated on: November 27, 2023 Written by: John Loukidelis
A taxpayer can deduct an amount under paragraph 20(1)(ww) even if the taxpayer must include a taxable capital gain in income that is subject to TOSI but he or she can offset the gain with an allowable capital loss. STEP…
Continue reading “Deduction for TOSI under 20(1)(ww)”…

Trusts and control

Posted on: November 29, 2023 Last updated on: November 27, 2023 Written by: John Loukidelis
The CRA accepts that, if A and B are the trustees of a trust that controls Corp1, and A and B also constitute a group that controls Corp2, then Corp1 and Corp2 are related to each other under subparagraph 251(2)(c)(i).…
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Preparer penalties

Posted on: November 28, 2023 Last updated on: November 28, 2023 Written by: John Loukidelis
I have become aware of a case where the CRA has imposed preparer penalties on an accountant who filed tax returns for corporations and their shareholders where the shareholders did not report income in respect of shareholder loan debit balances…
Continue reading “Preparer penalties”…

Post Number 1,000

Posted on: November 27, 2023 Last updated on: November 27, 2023 Written by: John Loukidelis
This post is number 1,000 in this, my blog about Canadian income tax law. I have been writing here more or less regularly, since August, 2005. I started writing the blog as a way of informing clients about recent developments…
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Reporting the ID of disaster clause beneficiaries

Posted on: November 23, 2023 Last updated on: November 15, 2023 Written by: John Loukidelis
At the STEP Canada 2023 Round Table, in answer to question 4, the CRA stated that a contingent beneficiary is a beneficiary for the purposes of subsection 204.2(2) of the Income Tax Regulations, which now requires trusts to provide identification…
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Property of a trust that prevents the prevention of filing

Posted on: November 20, 2023 Last updated on: June 27, 2024 Written by: John Loukidelis
At the STEP Canada 2023 Round Table, in answer to question 3, the CRA stated that a trust settled with a gold or silver bar, or a collectible coin, cannot satisfy the exception in paragraph 150(1.2)(b) of the Income Tax…
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Forgotten capital losses

Posted on: November 15, 2023 Last updated on: November 15, 2023 Written by: John Loukidelis
At the STEP Canada 2023 Round Table, in question 2, the CRA addressed a hypothetical question about the executors of an estate finding evidence of a capital loss realized years before that was not claimed. The CRA agreed that the…
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Notifiable transactions list

Posted on: November 1, 2023 Last updated on: November 1, 2023 Written by: John Loukidelis
The CRA has posted the list of notifiable transactions that have been designated by the Minister of National Revenue effective today. In the email I received notifying me of the notifiable transactions list, the CRA wrote “The list of transactions…
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Dividends paid to beneficiaryco, again

Posted on: October 26, 2023 Last updated on: October 26, 2023 Written by: John Loukidelis
In Vefghi Holding Corp. v R, 2023 TCC 135, the court provided the following answers to a Rule 58 Question: Where a trust designates a portion of a taxable dividend (the “Amount”) received on a share of the capital stock…
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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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