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LPC Notes (page 100)

Rights and an Ombudsman

Posted on: May 28, 2007 Last updated on: May 28, 2007 Written by: John Loukidelis
A CRA press release just announced a “new” Taxpayer Bill of Rights (isn’t that old news?) and the creation of a Taxpayers’ Ombudsman. I can just imagine the paper piling up at the latter’s office within about 15 seconds of…
Continue reading “Rights and an Ombudsman”…

LLCs

Posted on: May 24, 2007 Last updated on: May 24, 2007 Written by: John Loukidelis

Last week’s CCH Tax Topics has an interesting article on limited liability companies (LLCs) in light of the B.C. Supreme Court’s decision in Boliden Westmin Ltd. et al. v. The Queen, 2007 BCSC 351.

Continue reading “LLCs”…

Bill C-52 Update

Posted on: May 16, 2007 Last updated on: May 16, 2007 Written by: John Loukidelis
Bill C-52 received second reading yesterday and was referred to committee.
Continue reading “Bill C-52 Update”…

Bill C-33 update

Posted on: May 15, 2007 Last updated on: May 15, 2007 Written by: John Loukidelis
Bill C-33 has received second reading and has been referred to committee.
Continue reading “Bill C-33 update”…

Ontario Corporations Act Update

Posted on: May 11, 2007 Last updated on: May 11, 2007 Written by: John Loukidelis
The Ontario government has announced that it “is undertaking a project to review and reform the Ontario Corporations Act (CA)”. The government is inviting “comments and suggestions from stakeholders and from the public regarding the reform of this important legislation.”
Continue reading “Ontario Corporations Act Update”…

Charity Law Symposium

Posted on: May 10, 2007 Last updated on: May 10, 2007 Written by: John Loukidelis
I spoke about split receipts at the Canadian Bar Association’s National Charity Law Symposium in Toronto today. You can download my presentation here. You can also download a “decision tree” that highlights the issues to be considered in issuing split…
Continue reading “Charity Law Symposium”…

Redeemer Goes to Ottawa

Posted on: May 10, 2007 Last updated on: May 10, 2007 Written by: John Loukidelis
The Supreme Court of Canada today granted Redeemer Foundation’s “application for leave to appeal with costs to the applicant in any event of the cause.” The plot thickens. For my comments on this case, search for “Redeemer” on this…
Continue reading “Redeemer Goes to Ottawa”…

Debate on Bill C-33

Posted on: May 5, 2007 Last updated on: May 5, 2007 Written by: John Loukidelis

The House of Commons is now debating Bill C-33 at second reading. You can get the flavour of the debate by reading the speech of Mr. Massimo Pacetti (Saint-Léonard—Saint-Michel, Lib.), which reads in part:

Continue reading “Debate on Bill C-33”…

Voluntary disclosure update

Posted on: May 5, 2007 Last updated on: May 5, 2007 Written by: John Loukidelis
The CRA has posted an update on its no-names voluntary disclosure program.
Continue reading “Voluntary disclosure update”…

Trouble for a charity

Posted on: April 30, 2007 Last updated on: April 30, 2007 Written by: John Loukidelis
I reported on a tax case involving All Saints Greek Orthodox Church here. Now the Toronto Star is reporting that the church issued receipts with a total value of about $273 million as part of the program under audit in…
Continue reading “Trouble for a charity”…
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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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