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Category: 14.1 property

No rollover for voluntary dispositions of farm quota

Posted on: December 19, 2016 Last updated on: December 19, 2016 Written by: John Loukidelis
In technical interpretation 2016-0666901E5, the CRA was asked whether the new rules applicable to farm quota after 2016 will provide for a rollover equivalent to the one found in s 14(6) of the ITA for voluntary dispositions of quota. The…
Continue reading “No rollover for voluntary dispositions of farm quota”…

Farm quota as 14.1 Property

Posted on: November 9, 2016 Last updated on: November 9, 2016 Written by: John Loukidelis

CRA technical interpretation 2016-0660861E5 dated September 27, 2016, provides a handy summary of how the transitional rules will work for milk quota that changes from eligible capital property (ECP) to Class 14.1 depreciable capital property (14.1 property) especially where only some of the quota is sold after 2016.

Continue reading “Farm quota as 14.1 Property”…

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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?”…

Capital gain exemption fail

I wrote the following article for the Hamilton Law Association Journal on Ehresman v R, 2025 TCC 78. For another summary of the case, see Colin Bartlett “Are Excess Cash Reserves an Active Business Asset?” 25:4 Tax for the Owner-Manager…
Continue reading “Capital gain exemption fail”…

Relevant group entities

A relevant group entity (RGE) of a corporation (per subaparagraphs 84.1(2.31)(c)(iii) and 84.1(2.32)(c)(iii) in the intergenerational transfer (IGT) rules) is any entity carrying on an active business that is relevant to whether the corporation’s shares are qualified small business corporation…
Continue reading “Relevant group entities”…

Recent Posts

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?”…

Capital gain exemption fail

I wrote the following article for the Hamilton Law Association Journal on Ehresman v R, 2025 TCC 78. For another summary of the case, see Colin Bartlett “Are Excess Cash Reserves an Active Business Asset?” 25:4 Tax for the Owner-Manager…
Continue reading “Capital gain exemption fail”…

Relevant group entities

A relevant group entity (RGE) of a corporation (per subaparagraphs 84.1(2.31)(c)(iii) and 84.1(2.32)(c)(iii) in the intergenerational transfer (IGT) rules) is any entity carrying on an active business that is relevant to whether the corporation’s shares are qualified small business corporation…
Continue reading “Relevant group entities”…

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Archives

Categories

Recent Posts

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?”…

Capital gain exemption fail

I wrote the following article for the Hamilton Law Association Journal on Ehresman v R, 2025 TCC 78. For another summary of the case, see Colin Bartlett “Are Excess Cash Reserves an Active Business Asset?” 25:4 Tax for the Owner-Manager…
Continue reading “Capital gain exemption fail”…

Relevant group entities

A relevant group entity (RGE) of a corporation (per subaparagraphs 84.1(2.31)(c)(iii) and 84.1(2.32)(c)(iii) in the intergenerational transfer (IGT) rules) is any entity carrying on an active business that is relevant to whether the corporation’s shares are qualified small business corporation…
Continue reading “Relevant group entities”…

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