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Category: Attribution

Attribution in action

Posted on: June 5, 2024 Last updated on: June 5, 2024 Written by: John Loukidelis
Suppose that A and B are spouses, that they purchase a cottage together for $400,000 and that A contributes $100,000 toward the satisfaction of that purchase price. The balance is financed, with A and B paying the principal and interest…
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Corporate attribution tips

Posted on: May 11, 2022 Last updated on: May 4, 2022 Written by: John Loukidelis
The authors summarize some methods for avoiding or mitigating corporate attribution: The corporate attribution rules do not apply where the transferee is a small business corporation. The transferor could consider effecting a freeze using a stock dividend. (But will the…
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Prescribed rate loan

Posted on: November 14, 2020 Last updated on: November 14, 2020 Written by: John Loukidelis
In response to question 11 at the 2020 Canadian Tax Foundation Roundtable, the CRA said that a prescribed rate loan could be refinanced at a lower rate by selling property acquired with the first loan, repay the first loan and…
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Corporate attribution

Posted on: July 9, 2018 Last updated on: November 14, 2020 Written by: John Loukidelis
Manu Kakkar, Alex Ghani and Boris Volvofsky, in “Corporate Attribution: Refreeze May Cause Unsolvable Corporate Attribution Problem” 18:3 Tax for the Owner-Manager (July, 2018), argue that a refreeze at a lower value does not reduce the outstanding amount for the…
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Clever planning

Posted on: July 26, 2017 Last updated on: July 26, 2017 Written by: John Loukidelis

The Tax Court continues to be unimpressed by clever planning. Brian Arnold thinks that the current generation of tax judges is much more willing to apply the GAAR or other anti-avoidance rules to planning that reduces tax. Mady v R, 2017 TCC 112, is another case that supports his thesis.

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VD Info Circular Updated

I just updated my webpage article on voluntary disclosures, which addresses the CRA’s amended policy on VDs found in IC00-1R7 (Voluntary Disclosures Program).
Continue reading “VD Info Circular Updated”…

Poker appeals dismissed

The taxpayers’ appeals in the poker winnings trilogy of cases have been dismissed: Fournier-Giguère v R, 2025 FCA 112. English translations of the Tax Court decisions are now available. See 2022 TCC 132 (Fournier‑Giguère Judgment), 2023 TCC 3 (D’Auteuil Judgment)…
Continue reading “Poker appeals dismissed”…

Twenty years

Today is the 20th anniversary of this blog. I made my first post on it on August 22, 2005. I’m now working on post number 1,077.
Continue reading “Twenty years”…

Shares acquired by a trust are QSBCSs

On January 1, 2023, a newly-formed personal trust purchased shares of Opco from Dad, who owned them throughout the preceding two years. The trust sold the shares on June 30, 2023, to an unrelated person. The CRA found that the…
Continue reading “Shares acquired by a trust are QSBCSs”…

TOSI and a power of attorney

Son is the owner of 10 out of 100 issued Common Shares in the capital of Opco, which are the only issued shares of the corporation. Son grants a power of attorney to his father to exercise all rights to…
Continue reading “TOSI and a power of attorney”…

Recent Posts

VD Info Circular Updated

I just updated my webpage article on voluntary disclosures, which addresses the CRA’s amended policy on VDs found in IC00-1R7 (Voluntary Disclosures Program).
Continue reading “VD Info Circular Updated”…

Poker appeals dismissed

The taxpayers’ appeals in the poker winnings trilogy of cases have been dismissed: Fournier-Giguère v R, 2025 FCA 112. English translations of the Tax Court decisions are now available. See 2022 TCC 132 (Fournier‑Giguère Judgment), 2023 TCC 3 (D’Auteuil Judgment)…
Continue reading “Poker appeals dismissed”…

Twenty years

Today is the 20th anniversary of this blog. I made my first post on it on August 22, 2005. I’m now working on post number 1,077.
Continue reading “Twenty years”…

Shares acquired by a trust are QSBCSs

On January 1, 2023, a newly-formed personal trust purchased shares of Opco from Dad, who owned them throughout the preceding two years. The trust sold the shares on June 30, 2023, to an unrelated person. The CRA found that the…
Continue reading “Shares acquired by a trust are QSBCSs”…

TOSI and a power of attorney

Son is the owner of 10 out of 100 issued Common Shares in the capital of Opco, which are the only issued shares of the corporation. Son grants a power of attorney to his father to exercise all rights to…
Continue reading “TOSI and a power of attorney”…

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Archives

Categories

Recent Posts

VD Info Circular Updated

I just updated my webpage article on voluntary disclosures, which addresses the CRA’s amended policy on VDs found in IC00-1R7 (Voluntary Disclosures Program).
Continue reading “VD Info Circular Updated”…

Poker appeals dismissed

The taxpayers’ appeals in the poker winnings trilogy of cases have been dismissed: Fournier-Giguère v R, 2025 FCA 112. English translations of the Tax Court decisions are now available. See 2022 TCC 132 (Fournier‑Giguère Judgment), 2023 TCC 3 (D’Auteuil Judgment)…
Continue reading “Poker appeals dismissed”…

Twenty years

Today is the 20th anniversary of this blog. I made my first post on it on August 22, 2005. I’m now working on post number 1,077.
Continue reading “Twenty years”…

Shares acquired by a trust are QSBCSs

On January 1, 2023, a newly-formed personal trust purchased shares of Opco from Dad, who owned them throughout the preceding two years. The trust sold the shares on June 30, 2023, to an unrelated person. The CRA found that the…
Continue reading “Shares acquired by a trust are QSBCSs”…

TOSI and a power of attorney

Son is the owner of 10 out of 100 issued Common Shares in the capital of Opco, which are the only issued shares of the corporation. Son grants a power of attorney to his father to exercise all rights to…
Continue reading “TOSI and a power of attorney”…

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