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Category: CRA News (page 7)

Shakedown?

Posted on: April 26, 2011 Last updated on: April 26, 2011 Written by: John Loukidelis
I hate to think that a CRA auditor could use the considerable powers at his disposal for a shakedown, but the RCMP is investigating just such a possibility.
Continue reading “Shakedown?”…

Disability crackdown?

Posted on: February 10, 2011 Last updated on: February 10, 2011 Written by: John Loukidelis
In my experience, the CRA has always been pretty careful—some would say overly stingy—about allowing disability tax credits, but, according to a Toronto Star–CBC investigation, that hasn’t stopped abuses of the system. I wonder how many Canadians with real disabilities…
Continue reading “Disability crackdown?”…

GST44

Posted on: October 28, 2010 Last updated on: October 28, 2010 Written by: John Loukidelis
The CRA just released a new version of GST44, the form used for elections under section 167 of the GST legislation.
Continue reading “GST44”…

CRA Trusts Initiative

Posted on: October 21, 2010 Last updated on: October 21, 2010 Written by: John Loukidelis

I spoke at an Ontario Bar Association conference on October 2 along with David Louis from Minden Gross (among others). David’s presentation included some discussion of the CRA trust audit initiative about which we’ve heard so much. David had contacted the CRA’s Toronto TSO about the initiative, and it told him the following:

Continue reading “CRA Trusts Initiative”…

No New Policy for VDs

Posted on: October 6, 2010 Last updated on: October 6, 2010 Written by: John Loukidelis
In July, The Globe and Mail was reporting that the CRA was getting ready to “relax the rules for confessing secret, offshore accounts”. Apparently the CRA was considering a new policy that would have required taxpayers to go back only…
Continue reading “No New Policy for VDs”…

Tax Cheats

Posted on: September 30, 2010 Last updated on: September 30, 2010 Written by: John Loukidelis
The Prime Minister has promised that the CRA will chase tax cheats. The PM made this promise in the wake of the release of a CBC News-Globe and Mail report on offshore bank accounts at HSBC in Switzerland.
Continue reading “Tax Cheats”…

Partnership Filings

Posted on: September 18, 2010 Last updated on: September 18, 2010 Written by: John Loukidelis
The following is from a news release posted to the CRA website yesterday: Starting in 2011, the requirement related to the number of partners in a partnership will be replaced with a new requirement based on financial activity. Also, the…
Continue reading “Partnership Filings”…

Some Big Numbers on Charity Tax Shelters

Posted on: September 15, 2010 Last updated on: September 15, 2010 Written by: John Loukidelis
Today’s Globe and Mail reports that the CRA has reassessed, or soon will reassess, up to 170,000 Canadians “who have allegedly claimed $5-billion in bogus charitable donations since 2003 by using controversial tax shelter programs.”
Continue reading “Some Big Numbers on Charity Tax Shelters”…

Prescribed rates for 2010 Q4

Posted on: September 10, 2010 Last updated on: September 10, 2010 Written by: John Loukidelis
The CRA was tardy about publishing the prescribed rates for 2010 Q3. It seems to have wanted to make up for it by publishing the rates for 2010 Q4 early.
Continue reading “Prescribed rates for 2010 Q4”…

Auto Expenses

Posted on: September 2, 2010 Last updated on: September 2, 2010 Written by: John Loukidelis

The CRA website now includes a post on the new method for keeping track of motor vehicle expenses.

Continue reading “Auto Expenses”…
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Directors of a dissolved corporation

In 2008, I wrote an article for the Hamilton Law Association Journal that, among other things, addressed the status of directors of a corporation that has been dissolved. I referred to Leger v R, 2007 TCC 322, which held that,…
Continue reading “Directors of a dissolved corporation”…

DAC Investment

The authors discuss R v DAC Investment Holdings Inc., 2026 FCA 35, rev’g 2024 TCC 63. They conclude that, in a GAAR analysis, an overly-broad characterization of a provision or a mere description of its effect will not correctly express its object, spirit and purpose…
Continue reading “DAC Investment”…

Limits on CRA demands for information

In Canada (National Revenue) v Cohen, 2025 FC 2012, the Court dismissed a Crown application for a compliance order because the taxpayer had demonstrated, on a balance of probabilities, that he had done everything reasonably possible to obtain the documents…
Continue reading “Limits on CRA demands for information”…

Post-mortem bumps and grandchildren

The bump under ITA paragraph 88(1)(d) could be denied if a “specified shareholder” receives bumped property unless the shareholder was also a “specified person” as defined in paragraph 88(1)(c.2). Grandchildren who receive bumped property could taint the bump if they…
Continue reading “Post-mortem bumps and grandchildren”…

Post-mortem bumps and capital dividends paid from life insurance

Bump room is determined by the ACB of the target corporation’s shares minus the net tax cost of the underlying assets and the amounts in ITA subparagraph 88(1)(d)(i.1), which include taxable dividends and capital dividends. Accordingly, a target corporation that…
Continue reading “Post-mortem bumps and capital dividends paid from life insurance”…

Recent Posts

Directors of a dissolved corporation

In 2008, I wrote an article for the Hamilton Law Association Journal that, among other things, addressed the status of directors of a corporation that has been dissolved. I referred to Leger v R, 2007 TCC 322, which held that,…
Continue reading “Directors of a dissolved corporation”…

DAC Investment

The authors discuss R v DAC Investment Holdings Inc., 2026 FCA 35, rev’g 2024 TCC 63. They conclude that, in a GAAR analysis, an overly-broad characterization of a provision or a mere description of its effect will not correctly express its object, spirit and purpose…
Continue reading “DAC Investment”…

Limits on CRA demands for information

In Canada (National Revenue) v Cohen, 2025 FC 2012, the Court dismissed a Crown application for a compliance order because the taxpayer had demonstrated, on a balance of probabilities, that he had done everything reasonably possible to obtain the documents…
Continue reading “Limits on CRA demands for information”…

Post-mortem bumps and grandchildren

The bump under ITA paragraph 88(1)(d) could be denied if a “specified shareholder” receives bumped property unless the shareholder was also a “specified person” as defined in paragraph 88(1)(c.2). Grandchildren who receive bumped property could taint the bump if they…
Continue reading “Post-mortem bumps and grandchildren”…

Post-mortem bumps and capital dividends paid from life insurance

Bump room is determined by the ACB of the target corporation’s shares minus the net tax cost of the underlying assets and the amounts in ITA subparagraph 88(1)(d)(i.1), which include taxable dividends and capital dividends. Accordingly, a target corporation that…
Continue reading “Post-mortem bumps and capital dividends paid from life insurance”…

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Archives

Categories

Recent Posts

Directors of a dissolved corporation

In 2008, I wrote an article for the Hamilton Law Association Journal that, among other things, addressed the status of directors of a corporation that has been dissolved. I referred to Leger v R, 2007 TCC 322, which held that,…
Continue reading “Directors of a dissolved corporation”…

DAC Investment

The authors discuss R v DAC Investment Holdings Inc., 2026 FCA 35, rev’g 2024 TCC 63. They conclude that, in a GAAR analysis, an overly-broad characterization of a provision or a mere description of its effect will not correctly express its object, spirit and purpose…
Continue reading “DAC Investment”…

Limits on CRA demands for information

In Canada (National Revenue) v Cohen, 2025 FC 2012, the Court dismissed a Crown application for a compliance order because the taxpayer had demonstrated, on a balance of probabilities, that he had done everything reasonably possible to obtain the documents…
Continue reading “Limits on CRA demands for information”…

Post-mortem bumps and grandchildren

The bump under ITA paragraph 88(1)(d) could be denied if a “specified shareholder” receives bumped property unless the shareholder was also a “specified person” as defined in paragraph 88(1)(c.2). Grandchildren who receive bumped property could taint the bump if they…
Continue reading “Post-mortem bumps and grandchildren”…

Post-mortem bumps and capital dividends paid from life insurance

Bump room is determined by the ACB of the target corporation’s shares minus the net tax cost of the underlying assets and the amounts in ITA subparagraph 88(1)(d)(i.1), which include taxable dividends and capital dividends. Accordingly, a target corporation that…
Continue reading “Post-mortem bumps and capital dividends paid from life insurance”…

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