The following are my notes on an international tax update from Steven Suarez given at an OBA taxation law presentation on September 22, 2020 (“Advising your clients amidst financial uncertainty: Summer 2020 tax developments”) For the paper, see ~\Knowledge\Seminar materials\2020…
Joint Committee update
The following are my notes on an update from Angelo Nikolakakis given at an OBA taxation law presentation on September 22, 2020 (“Advising your clients amidst financial uncertainty: Summer 2020 tax developments”) For the paper, see ~\Knowledge\Seminar materials\2020 09 22…
Hockey players and fx trading
The Toronto Star is reporting that Darcy Tucker and Shayne Corson of Toronto Maple Leaf fame engaged in foreign exchange trading a reported losses for tax purposes. The CRA is calling the trading activities a “sham” (which doesn’t mean what…
Change of trustee and acquisitions of control
The CRA takes the position that, where a new individual becomes a trustee, a corporation controlled by the trust is controlled by a new group so that there will be an acquisition of control unless one of the exceptions in…
Pipeline Update
The CRA usually requires that an estate wait for at least a year to receive repayments from the note issued by Newco as part of a pipeline, and the repayments that begin at that time must be spread out over…
Section 325 and Joint Bank Accounts
In White v R, 2020 TCC 22, the taxpayer’s husband owed tax debts under the Excise Tax Act at a time when he made deposits to their joint bank account. The issue was whether the taxpayer was liable under section…
Section 160 and Director Liability
In R v Colitto, 2020 FCA 70, rev’g 2019 TCC 88, the Court considered when the liability of a director arises under section 227.1 of the Income Tax Act (Canada) (the “Act”) for the purposes of section 160 of the…
We have moved!
We have moved! We are still at 20 Hughson St S in Hamilton, but our new suite number is 707. All of our other contact details remain the same. Our updated contact information can be found here. Because of COVID-19,…
COVID-19 update
Our office remains closed for now even as the province re-opens after the pandemic. We continue to serve our clients, however, by phone and by email. Our contact information can be found here.
Excess CDA election
A corporation purports to pay a capital dividend, but a portion of the dividend is in excess of the balance of the corporation’s capital dividend account (CDA). The corporation pays Part III tax on the excess rather than elect under…