• Skip to main navigation
  • Skip to main content
  • Skip to footer
Loukidelis PC

Loukidelis PC

Effective. Accessible. Responsive

  • Services
  • About
  • LPC Notes
  • Articles
  • Privacy Policy
  • Contact Us
  • Disclaimer
  • Skip to menu toggle button

LPC Notes (page 83)

Nerd update

Posted on: April 3, 2009 Last updated on: April 3, 2009 Written by: John Loukidelis
In the interests of doing my part to be part of Web 2.0, I’ve deleted my page on this blog devoted to links of interest to tax practitioners, and I’ve created a page of links at delicious.com instead. Those of…
Continue reading “Nerd update”…

Tax Nerd

Posted on: April 2, 2009 Last updated on: April 2, 2009 Written by: John Loukidelis
Paragraph 149.1(4)(c) in my version of the Practitioner’s Income Tax Act (35th edition) is missing an “or” at the end of it. I emailed David Sherman, the PITA editor, about this, and he confirmed that the “or” was missing in…
Continue reading “Tax Nerd”…

Election for Restrictive Covenants

Posted on: March 27, 2009 Last updated on: March 27, 2009 Written by: John Loukidelis
Bryan Walters at Wade Group was kind enough to forward to me a link to the five-page “election letter” that the CRA wants taxpayers to use who are making elections under subsection 56.4(3) of the Income Tax Act.
Continue reading “Election for Restrictive Covenants”…

Local flavour

Posted on: March 12, 2009 Last updated on: March 12, 2009 Written by: John Loukidelis
Here’s a case with some local flavour, of a sort: Dundurn Street Loffts Inc. v. The Queen, 2009 TCC 122.
Continue reading “Local flavour”…

Class action

Posted on: March 9, 2009 Last updated on: March 9, 2009 Written by: John Loukidelis
Sorbara v. Canada (Attorney General), 2008 CanLII 61246 (ON S.C.) is an interesting case about class action proceedings and Tax Court appeals. The moral of the story: the Tax Court has exclusive jurisdiction over tax matters even though it (probably)…
Continue reading “Class action”…

Budget bill

Posted on: March 7, 2009 Last updated on: March 7, 2009 Written by: John Loukidelis
Bill C-10, “An Act to implement certain provisions of the budget tabled in Parliament on January 27, 2009 and related fiscal measures”, has received second reading in the Senate and been referred to committee.
Continue reading “Budget bill”…

The Exemption

Posted on: March 4, 2009 Last updated on: March 4, 2009 Written by: John Loukidelis
I delivered a paper on the capital gains exemption at the Ontario Bar Association yesterday in Toronto at a conference for estates and trusts lawyers.
Continue reading “The Exemption”…

Crazy

Posted on: February 23, 2009 Last updated on: February 23, 2009 Written by: John Loukidelis

In an article I wrote about three years ago, I pointed out that the purveyors of tax snake oil seemed to be having some success convincing their “clients” that they need not pay income tax.

Continue reading “Crazy”…

HLA Paper on Trusts and Estates

Posted on: February 23, 2009 Last updated on: February 23, 2009 Written by: John Loukidelis
I delivered a paper last week at the Hamilton Law Association‘s trusts and estates update. My paper focused on tax issues, of course. The session was very well attended, with well over 100 members of the local bar present.
Continue reading “HLA Paper on Trusts and Estates”…

New forms

Posted on: February 18, 2009 Last updated on: February 18, 2009 Written by: John Loukidelis
The CRA recently issued revised versions of a number of forms and publications, including the T2057 and the “T4001 Employers’ Guide – Payroll Deductions and Remittances”.
Continue reading “New forms”…
« Previous page 1 … 81 82 83 84 85 … 109 Next page »

Archives

Categories

Recent notes

Post-mortem bumps and capital dividends paid from life insurance

Bump room is determined by the ACB of the target corporation’s shares minus the net tax cost of the underlying assets and the amounts in ITA subparagraph 88(1)(d)(i.1), which include taxable dividends and capital dividends. Accordingly, a target corporation that…
Continue reading “Post-mortem bumps and capital dividends paid from life insurance”…

IBTs and the 88(1)(d) bump

In an intergenerational business transfer (IBT), the purchaser does not generally acquire control of the targetco for the purposes of the rule in ITA paragraph 88(1)(d.2). As a result, the tax cost of the eligible assets of targetco likely cannot…
Continue reading “IBTs and the 88(1)(d) bump”…

No obligation to correct past errors

The CRA believes that a tax adviser should takes steps to ensure their clients correct past errors (I01-1R2 (February 17, 2026), paras. 116-117), but neither the Income Tax Act nor the Excise Tax Act impose such a duty. Other statutes…
Continue reading “No obligation to correct past errors”…

Timing of receipt of dividend on redemption

Under subsection 84(3) of the Income Tax Act (Canada) (the “Act”), where a corporation resident in Canada has redeemed, acquired or cancelled in any manner whatever … any of the shares of any class of its capital stock, (a) the…
Continue reading “Timing of receipt of dividend on redemption”…

GLGI appeals to be struck?

In Kelly v R, 2026 TCC 53, Justice Graham has given multiple taxpayers until April 24, 2026, to provide written submissions on why their appeals should not be struck without a hearing “for abusing this Court’s process”. The taxpayers were…
Continue reading “GLGI appeals to be struck?”…

Recent Posts

Post-mortem bumps and capital dividends paid from life insurance

Bump room is determined by the ACB of the target corporation’s shares minus the net tax cost of the underlying assets and the amounts in ITA subparagraph 88(1)(d)(i.1), which include taxable dividends and capital dividends. Accordingly, a target corporation that…
Continue reading “Post-mortem bumps and capital dividends paid from life insurance”…

IBTs and the 88(1)(d) bump

In an intergenerational business transfer (IBT), the purchaser does not generally acquire control of the targetco for the purposes of the rule in ITA paragraph 88(1)(d.2). As a result, the tax cost of the eligible assets of targetco likely cannot…
Continue reading “IBTs and the 88(1)(d) bump”…

No obligation to correct past errors

The CRA believes that a tax adviser should takes steps to ensure their clients correct past errors (I01-1R2 (February 17, 2026), paras. 116-117), but neither the Income Tax Act nor the Excise Tax Act impose such a duty. Other statutes…
Continue reading “No obligation to correct past errors”…

Timing of receipt of dividend on redemption

Under subsection 84(3) of the Income Tax Act (Canada) (the “Act”), where a corporation resident in Canada has redeemed, acquired or cancelled in any manner whatever … any of the shares of any class of its capital stock, (a) the…
Continue reading “Timing of receipt of dividend on redemption”…

GLGI appeals to be struck?

In Kelly v R, 2026 TCC 53, Justice Graham has given multiple taxpayers until April 24, 2026, to provide written submissions on why their appeals should not be struck without a hearing “for abusing this Court’s process”. The taxpayers were…
Continue reading “GLGI appeals to be struck?”…

Archives

Categories

Meta

  • Log in
  • Entries feed
  • Comments feed
  • WordPress.org

About this site

Click here for an important disclaimer about this site.

Archives

Categories

Recent Posts

Post-mortem bumps and capital dividends paid from life insurance

Bump room is determined by the ACB of the target corporation’s shares minus the net tax cost of the underlying assets and the amounts in ITA subparagraph 88(1)(d)(i.1), which include taxable dividends and capital dividends. Accordingly, a target corporation that…
Continue reading “Post-mortem bumps and capital dividends paid from life insurance”…

IBTs and the 88(1)(d) bump

In an intergenerational business transfer (IBT), the purchaser does not generally acquire control of the targetco for the purposes of the rule in ITA paragraph 88(1)(d.2). As a result, the tax cost of the eligible assets of targetco likely cannot…
Continue reading “IBTs and the 88(1)(d) bump”…

No obligation to correct past errors

The CRA believes that a tax adviser should takes steps to ensure their clients correct past errors (I01-1R2 (February 17, 2026), paras. 116-117), but neither the Income Tax Act nor the Excise Tax Act impose such a duty. Other statutes…
Continue reading “No obligation to correct past errors”…

Timing of receipt of dividend on redemption

Under subsection 84(3) of the Income Tax Act (Canada) (the “Act”), where a corporation resident in Canada has redeemed, acquired or cancelled in any manner whatever … any of the shares of any class of its capital stock, (a) the…
Continue reading “Timing of receipt of dividend on redemption”…

GLGI appeals to be struck?

In Kelly v R, 2026 TCC 53, Justice Graham has given multiple taxpayers until April 24, 2026, to provide written submissions on why their appeals should not be struck without a hearing “for abusing this Court’s process”. The taxpayers were…
Continue reading “GLGI appeals to be struck?”…

© Loukidelis Professional Corporation