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Category: Corporations (page 3)

256(6) and Indemnities

Posted on: March 15, 2015 Last updated on: March 15, 2015 Written by: John Loukidelis
According to CRA technical interpretation 2015-0565741E5, subsection 256(6) will not save the CCPC status of a corporation whose shares are pledged to secure an indemnity. The CRA concluded that an indemnity is not a debt for the purposes of the…
Continue reading “256(6) and Indemnities”…

Notes on Shares of a Specified Class

Posted on: March 6, 2015 Last updated on: March 6, 2015 Written by: John Loukidelis
In applying the association rules in subsection 256(1) of the Income Tax Act (Canada), one can ignore shares of a specified class as defined in subsection 256(1.1). The CRA has said the following about that definition. Regarding the requirements in…
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Currency swaps

Posted on: February 25, 2015 Last updated on: February 25, 2015 Written by: John Loukidelis
Craig Burley has written a good short post on George Weston Limited v R, 2015 TCC 42, a case argued for the taxpayer by my old friend from law school days, Sal Mirandola.
Continue reading “Currency swaps”…

55(5)(f) designations are unnecessary?

Posted on: February 21, 2015 Last updated on: January 4, 2016 Written by: John Loukidelis
Neal Armstrong reports on the CRA pronouncement regarding 55(5)(f) designations at the 2014 STEP Roundtable: CRA stated that its long-standing practice “is to apply subsection 55(2) only to the excess of the taxable dividend paid on a share over the…
Continue reading “55(5)(f) designations are unnecessary?”…

MGS on strike?

Posted on: February 6, 2015 Last updated on: February 6, 2015 Written by: John Loukidelis
The following is from an OPSEU press release issued last week: The union representing 35,000 frontline Ministry employees who work directly for the Ontario government announced today that bargaining representatives of the Ontario Government have taken a significant step towards…
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84.1 and employee buycos

Posted on: January 20, 2015 Last updated on: January 20, 2015 Written by: John Loukidelis
I gave a talk today at the Hamilton Law Association on shareholder agreements and tax issues. David Howell asked me a question, on which I drew a blank, relating to employee buycos. Thanks to Shelley Wickenheiser, I was able to…
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Deemed ownership of shares

Posted on: January 18, 2015 Last updated on: January 18, 2015 Written by: John Loukidelis
I am giving a talk on Tuesday at the Hamilton Law Association on tax issues in shareholder agreements. From my speaking notes: The language of 251(5)(b) and subsection 256(1.4) appear to be very similar, but the CRA has maintained an…
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New folio on amalgamations

Posted on: December 2, 2014 Last updated on: December 2, 2014 Written by: John Loukidelis
The CRA has published a new folio on amalgamations here.
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Inter-company Management Fees

Posted on: October 26, 2014 Last updated on: October 26, 2014 Written by: John Loukidelis
A detailed services agreement was not enough by itself to justify the deduction of management fees paid by Opco to Holdco. The court wanted evidence of the services rendered, the service hours provided, the hourly rate and the identity of…
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Providing space

Posted on: October 20, 2014 Last updated on: October 20, 2014 Written by: John Loukidelis
Craig Burley has blogged about 0742443 BC Ltd v R, 2014 TCC 301. His takeaway on the case? “If you have a business that incorporates any sort of rental of space, or allowing customers to use your space, I recommend…
Continue reading “Providing space”…
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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”…

IGT, de facto control and notes

The immediate transfer regime under the intergenerational transfer (IGT) rules found in subsection 84.1(2.31) will not provide a safe harbour from section 84.1, if the taxpayer-vendor at any time after the sale, either alone or with a spouse, has de…
Continue reading “IGT, de facto control and notes”…

Transfer of property

Subsection 106(2) applies where a taxpayer disposes of an income interest in a trust. Paragraph 106(2)(a) requires the taxpayer to include in income an amount equal to the proceeds of disposition received for the interest less amounts included in the…
Continue reading “Transfer of property”…

Recent Posts

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”…

IGT, de facto control and notes

The immediate transfer regime under the intergenerational transfer (IGT) rules found in subsection 84.1(2.31) will not provide a safe harbour from section 84.1, if the taxpayer-vendor at any time after the sale, either alone or with a spouse, has de…
Continue reading “IGT, de facto control and notes”…

Transfer of property

Subsection 106(2) applies where a taxpayer disposes of an income interest in a trust. Paragraph 106(2)(a) requires the taxpayer to include in income an amount equal to the proceeds of disposition received for the interest less amounts included in the…
Continue reading “Transfer of property”…

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Archives

Categories

Recent Posts

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”…

IGT, de facto control and notes

The immediate transfer regime under the intergenerational transfer (IGT) rules found in subsection 84.1(2.31) will not provide a safe harbour from section 84.1, if the taxpayer-vendor at any time after the sale, either alone or with a spouse, has de…
Continue reading “IGT, de facto control and notes”…

Transfer of property

Subsection 106(2) applies where a taxpayer disposes of an income interest in a trust. Paragraph 106(2)(a) requires the taxpayer to include in income an amount equal to the proceeds of disposition received for the interest less amounts included in the…
Continue reading “Transfer of property”…

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