In Hypertec Systèmes inc. v Agence du revenu du Québec, 2025 QCCQ 6704, the taxpayer, the administrative entity for a corporate group, incurred about $1.3 million of professional fees in respect of a shareholder dispute that included a claim for…
Preliminary vs preparatory expenses
In Lienaux v R, 2025 TCC 67 (informal procedure), the Court referred to Vesuna v R, 2022 FCA 58, and Gartry v R, 1994 CanLII 19352 (TCC), in denying expenses incurred where the taxpayer had not actually started to carry…
Travel expense case
1048547 Ontario Inc. v R, 2023 TCC 24, illustrates the evidentiary burden a taxpayer will face when trying to justify travel expenses to exotic locations that seem to have nothing to do with the taxpayer’s ordinary business operations. If you…
Form matters, again
In David Anthony v Canada (National Revenue), 2016 FC 955, the taxpayer applied for judicial review of a decision of the Minister. The taxpayer had requested that the Minister adjust his return for 2001 to permit the deduction of lease…
Employee theft
Mark Tonkovich, “Theft by Owners or Senior Employees: Deductibility of Losses” (Feb 2016) 6:1 Canadian Tax Focus, analyzes employee theft as discussed in Income Tax Folio S3-F9-C1, “Lottery Winnings, Miscellaneous Receipts, and Income (and Losses) from Crime”. The Folio sets…
Run-off insurance
From CRA technical interpretation 2015-0618981E5 dated December 3, 2015: enerally speaking, the fact a taxpayer no longer carries on a business will not preclude the taxpayer from deducting Run-off Insurance premiums in the year they are paid, provided the insurance…