• 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

Category: Capital gain exemption

Shares acquired by a trust are QSBCSs

Posted on: August 21, 2025 Last updated on: August 15, 2025 Written by: John Loukidelis
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”…

Subsection 110.6(8) issues

Posted on: April 25, 2023 Last updated on: September 9, 2024 Written by: John Loukidelis
Subsection 110.6(8) denies the capital gain exemption for a gain on a share if insufficient dividends are paid on it and the share is not a “prescribed share”. An ordinary common share is a prescribed shares under Reg 6205(1). A…
Continue reading “Subsection 110.6(8) issues”…

Are persons related to themselves?

Posted on: October 27, 2021 Last updated on: October 27, 2021 Written by: John Loukidelis
When are persons related for the purposes of subparagraph 110.6(14)(c)(ii)? A person is not generally deemed to be related to himself except for certain purposes (paragraph 251(5)(c), subparagraph 55(5)(e)(ii), subsection 256(1.5) and determining whether corporations are associated). Compare this to…
Continue reading “Are persons related to themselves?”…

Crystallizing and estate planning

Posted on: April 29, 2016 Last updated on: April 29, 2016 Written by: John Loukidelis
Is it always a good idea to take full advantage of the capital gain exemption (CGE) by crystallizing? Assume Ms X crystallizes her Opco shares, but Opco morphs into an investment holding company by the time of her death. In…
Continue reading “Crystallizing and estate planning”…

Archives

Categories

Recent notes

Harvard Properties detailed notes

Harvard Properties 2024 TCC 139 per Boyle TCJ General procedure Under appeal A-382-24; A-388-24 “Another Section 160 Tax Avoidance Scam: Harvard Properties” Brian Arnold report 296 Jan 14/25 * Facts The following is a paraphrase of the facts set out…
Continue reading “Harvard Properties detailed notes”…

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”…

Recent Posts

Harvard Properties detailed notes

Harvard Properties 2024 TCC 139 per Boyle TCJ General procedure Under appeal A-382-24; A-388-24 “Another Section 160 Tax Avoidance Scam: Harvard Properties” Brian Arnold report 296 Jan 14/25 * Facts The following is a paraphrase of the facts set out…
Continue reading “Harvard Properties detailed notes”…

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”…

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

Harvard Properties detailed notes

Harvard Properties 2024 TCC 139 per Boyle TCJ General procedure Under appeal A-382-24; A-388-24 “Another Section 160 Tax Avoidance Scam: Harvard Properties” Brian Arnold report 296 Jan 14/25 * Facts The following is a paraphrase of the facts set out…
Continue reading “Harvard Properties detailed notes”…

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”…

© Loukidelis Professional Corporation