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Category: 9

Adventures in trade

Posted on: February 4, 2025 Last updated on: January 30, 2025 Written by: John Loukidelis
In Rudolph v R, 2024 TCC 148, the Court determined that gains and losses realized by the taxpayer on the sale of shares and the expiry of related options were on income account. The Court noted, among other things, that…
Continue reading “Adventures in trade”…

Sale of shares on income account

Posted on: December 19, 2024 Last updated on: December 19, 2024 Written by: John Loukidelis
In Rudolph v R, 2024 TCC 148, the Tax Court held that the taxpayer had not disposed of shares in 2007 as alleged by the CRA. Instead, the taxpayer had received a loan from the purchaser in 2007 that was…
Continue reading “Sale of shares on income account”…

Scams and tax

Posted on: January 10, 2024 Last updated on: January 10, 2024 Written by: John Loukidelis
In an email spoofing attack, an employee of a business might share important financial information with, or send money to a, a fraudster because the employee has received an email from the fraudster masquerading as the employee’s boss. In a…
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Stock options issued to a corporation

Posted on: September 23, 2022 Last updated on: September 23, 2022 Written by: John Loukidelis
Section 7 of the Income Tax Act (Canada) does not apply to stock options granted to a CCPC for consulting services rendered. Instead, “general tax principles” apply to determine when the CCPC must include an amount in income in respect…
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Happy Valley applied

Posted on: October 27, 2021 Last updated on: October 27, 2021 Written by: John Loukidelis
Happy Valley Farms Ltd. v MNR, 2 CTC 259, provides a handy list of the factors a court will generally consider in deciding whether a gain realized on the sale of a home was on income account. The Court…
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Inventory adjustment disallowed

Posted on: April 12, 2021 Last updated on: April 16, 2021 Written by: John Loukidelis
In Yorkwest Plumbing Supply Inc. v R, 2020 TCC 122, the Court considered an adjustment of $1.2 million that the taxpayer had made to its 2012 net income in respect of inventory that had been purchased and sold before the…
Continue reading “Inventory adjustment disallowed”…

TIP case

Posted on: April 12, 2021 Last updated on: April 16, 2021 Written by: John Loukidelis
Motter c Agence du revenue du Québec, 2021 QCCA 72, aff’g 2018 QCCQ 3483, found that tenant inducement payments “are not an expense category for the purpose of calculating income from a business or property, nor are they a subcategory…
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Bitcoin mining

Posted on: August 29, 2019 Last updated on: August 29, 2019 Written by: John Loukidelis
The CRA, in technical interpretation 2018-0776661I7 (August 8, 2019), takes the position that a Bitcoin miner receives Bitcoin as barter for services rendered. The transaction is a barter transaction because Bitcoin isn’t legal tender (see IT-490 “Barter Transactions”). The receipt…
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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”…

Receipts from fraudulent investment schemes

In Daniel Sze “Receipts from Fraudulent Schemes: When Are They Taxable?” Canadian Tax Focus 16:3 (August 2026), the author gives an overview of cases that have considered the taxation of amounts a taxpayer receives from a fraudulent “investment”. He notes…
Continue reading “Receipts from fraudulent investment schemes”…

Deductibility of professional fees

In Hypertec Systèmes inc. v Agence du revenu du Québec, 2025 QCCQ 6704, the taxpayer, the administrative entity for a corporate group, incurred about $1.3 million of professional fees in respect of a shareholder dispute that included a claim for…
Continue reading “Deductibility of professional fees”…

TFSA advantage “tax” is a-ok

I just wrote about TFSA over-contribution hell. The Federal Court of Appeal recently confirmed that the advantage “tax” is constitutional under section 53 of the Constitution Act, 1867 and that no due-diligence defence is available because it is a tax.…
Continue reading “TFSA advantage “tax” is a-ok”…

Recent Posts

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”…

Receipts from fraudulent investment schemes

In Daniel Sze “Receipts from Fraudulent Schemes: When Are They Taxable?” Canadian Tax Focus 16:3 (August 2026), the author gives an overview of cases that have considered the taxation of amounts a taxpayer receives from a fraudulent “investment”. He notes…
Continue reading “Receipts from fraudulent investment schemes”…

Deductibility of professional fees

In Hypertec Systèmes inc. v Agence du revenu du Québec, 2025 QCCQ 6704, the taxpayer, the administrative entity for a corporate group, incurred about $1.3 million of professional fees in respect of a shareholder dispute that included a claim for…
Continue reading “Deductibility of professional fees”…

TFSA advantage “tax” is a-ok

I just wrote about TFSA over-contribution hell. The Federal Court of Appeal recently confirmed that the advantage “tax” is constitutional under section 53 of the Constitution Act, 1867 and that no due-diligence defence is available because it is a tax.…
Continue reading “TFSA advantage “tax” is a-ok”…

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Archives

Categories

Recent Posts

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”…

Receipts from fraudulent investment schemes

In Daniel Sze “Receipts from Fraudulent Schemes: When Are They Taxable?” Canadian Tax Focus 16:3 (August 2026), the author gives an overview of cases that have considered the taxation of amounts a taxpayer receives from a fraudulent “investment”. He notes…
Continue reading “Receipts from fraudulent investment schemes”…

Deductibility of professional fees

In Hypertec Systèmes inc. v Agence du revenu du Québec, 2025 QCCQ 6704, the taxpayer, the administrative entity for a corporate group, incurred about $1.3 million of professional fees in respect of a shareholder dispute that included a claim for…
Continue reading “Deductibility of professional fees”…

TFSA advantage “tax” is a-ok

I just wrote about TFSA over-contribution hell. The Federal Court of Appeal recently confirmed that the advantage “tax” is constitutional under section 53 of the Constitution Act, 1867 and that no due-diligence defence is available because it is a tax.…
Continue reading “TFSA advantage “tax” is a-ok”…

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