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Category: CRA News (page 9)

New forms

Posted on: February 18, 2009 Last updated on: February 18, 2009 Written by: John Loukidelis
The CRA recently issued revised versions of a number of forms and publications, including the T2057 and the “T4001 Employers’ Guide – Payroll Deductions and Remittances”.
Continue reading “New forms”…

“Tax tip”

Posted on: December 2, 2008 Last updated on: December 2, 2008 Written by: John Loukidelis

“Did you know… That you should notify the Canada Revenue Agency (CRA) when directors of your corporation change?”

Continue reading ““Tax tip””…

Correcting 85 Election Forms

Posted on: April 25, 2008 Last updated on: April 25, 2008 Written by: John Loukidelis

The CRA’s Information Circular IC 76-19R3 sets out its position on the procedures for correcting T2057s (the form used for elections under section 85 of the Income Tax Act (Canada)). In effect, the Circular identifies two types of mistakes.

Continue reading “Correcting 85 Election Forms”…

Tax-Free Savings Accounts

Posted on: March 29, 2008 Last updated on: March 29, 2008 Written by: John Loukidelis
The CRA has taken to posting answers to frequently-asked questions about government goodies (aka Easter eggs hidden in the Income Tax Act). It has posted a useful guide to the new tax-free savings account proposed in the last budget.
Continue reading “Tax-Free Savings Accounts”…

Third parties

Posted on: December 12, 2007 Last updated on: December 12, 2007 Written by: John Loukidelis

One of my very first posts on this blog dealt with demands for information about third parties. The saga continues in Canada (National Revenue) v. The Greater Montréal Real Estate Board, 2006 FC 1069, in which the Court vacated its own ex parte order requiring the Board to turn over the information requested by the CRA. The Court founds as follows:

Continue reading “Third parties”…

10 Years

Posted on: December 12, 2007 Last updated on: December 12, 2007 Written by: John Loukidelis
In a post I wrote some time ago, I argued that the 10-year limitation rule for fairness (taxpayer relief) applications is ambiguous. I also noted that the CRA believes the rule is clear, and apparently it maintains that position still,…
Continue reading “10 Years”…

CRA Report

Posted on: December 8, 2007 Last updated on: December 8, 2007 Written by: John Loukidelis
The CRA has made its annual report to Parliament, and parts of it make for interesting reading. Essentially the report amounts to the CRA’s report card on itself. The report discusses outstanding tax debts among other things. The report notes…
Continue reading “CRA Report”…

News releases

Posted on: November 30, 2007 Last updated on: November 30, 2007 Written by: John Loukidelis
The CRA issued a couple of news releases yesterday. One of them warned about RSP “scams”, and the other announced that the CRA had issued a notice of suspension to ‘International Charity Association Network.’ The Department of Finance announced today…
Continue reading “News releases”…

More donation warnings

Posted on: November 21, 2007 Last updated on: November 21, 2007 Written by: John Loukidelis
The CRA is embarking on a media campaign to warn taxpayers about fraudulent charities and donation tax shelters. The CRA is cranking up its campaign on this issue, as I have noted previously. For more background, see my posts here…
Continue reading “More donation warnings”…

VDP news

Posted on: November 4, 2007 Last updated on: November 4, 2007 Written by: John Loukidelis
A couple of weeks ago, the CRA issued the new version of its information circular on voluntary disclosures (IC00-1R2). See also the form for a VD “taxpayer agreement“.
Continue reading “VDP news”…
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Recent notes

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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