How do subsection 55(2) and Part IV of the Income Tax Act (Canada) work together? The Tax Court considered this question recently in Ottawa Air Cargo Centre Ltd. v. The Queen, 2007 TCC 193 (“Air Cargo”).
LLCs
Last week’s CCH Tax Topics has an interesting article on limited liability companies (LLCs) in light of the B.C. Supreme Court’s decision in Boliden Westmin Ltd. et al. v. The Queen, 2007 BCSC 351.
Eligible dividends
Joe and I prepared a presentation for some area accountants on the new eligible dividend rules. You can download a copy here.
Property
Every now and then a taxpayer proposes to transfer an intangible “something” to a corporation for valuable consideration. The taxpayer, or his or her advisers, would do well to read Tri Pacific Gas Corporation v. Canada, 2007 FCA 38, before proceeding.
Eligible dividends
Joe and I will be giving a presentation on the new eligible dividend rules on Thursday, March 1, at noon at the Hamilton Chamber of Commerce. We will provide an overview of these rather complex rules and present some planning ideas and issues to consider.
De facto directors
An individual, even though not elected as a director by a corporation’s shareholders or shown as such in government records, can still be held liable for unremitted source deductions as a de facto director.
OBCA Amendments
In a post I wrote about stock dividends last fall, I mentioned that the Ontario government had tabled a bill to amend the Business Corporations Act to clarify that a nominal amount could be added to the stated capital of shares issued in satisfaction of a dividend.
Eligible dividends
The new eligible dividend rules require corporations “to designate each eligible dividend that they pay and notify shareholders in writing that the dividend is eligible.” The CRA issued a release just before Christmas that provides guidelines on how the designation…
Ontario simplifies
You have all read that the Ontario government plans to turn over the administration of its corporate income tax regime to the CRA. The government introduced draft legislation today to make that a reality. Now, when will the government muster…
Stock dividends
Stock dividends or “dividends satisfied by stock” can be a useful tool for a tax practitioner, but do they create their own tax problems for shareholders of a corporation incorporated under the Business Corporations Act (Ontario) (the “OBCA”)?