Integration – Loukidelis PC

CCPC over-integration increases

Decreases in the dividend tax credit for ineligible dividends has increased over-integration on investment income earned via a corporation for individuals who are in the top bracket. The extra burden arising from earning and receiving investment income via a corporation…

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Deductibility of professional fees

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…

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TFSA advantage “tax” is a-ok

I just wrote about TFSA over-contribution hell. The Federal Court of Appeal recently confirmed that the advantage “tax” is constitutional under section 53 of the Constitution Act, 1867 and that no due-diligence defence is available because it is a tax.…

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Part VI.1 tax

The Part VI.1 tax rules, which date from the late 1980s, can apply in unexpected and unhelpful ways to transactions that have nothing to do with the harm at which the rules were aimed. (The Department of Finance, in other…

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GLGI appeals struck

In a previous post, I discussed Kelly v R, 2026 TCC 53, in which Mr Justice Graham proposed to dismiss ongoing GLGI appeals as an abuse of process. Eight of the appellants to whom this proposal applied provided submissions for…

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Trusts and Association, Part Deux

This is the second part of a series on trusts and the association rules. The first part appeared in the May 2026 issue of Canadian Tax Focus. The second part addresses how the rules can apply. Divorced Spouses Divorced spouses…

Continue reading…

Deductibility of professional fees

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…

Continue reading…

TFSA advantage “tax” is a-ok

I just wrote about TFSA over-contribution hell. The Federal Court of Appeal recently confirmed that the advantage “tax” is constitutional under section 53 of the Constitution Act, 1867 and that no due-diligence defence is available because it is a tax.…

Continue reading…

Part VI.1 tax

The Part VI.1 tax rules, which date from the late 1980s, can apply in unexpected and unhelpful ways to transactions that have nothing to do with the harm at which the rules were aimed. (The Department of Finance, in other…

Continue reading…

GLGI appeals struck

In a previous post, I discussed Kelly v R, 2026 TCC 53, in which Mr Justice Graham proposed to dismiss ongoing GLGI appeals as an abuse of process. Eight of the appellants to whom this proposal applied provided submissions for…

Continue reading…

Trusts and Association, Part Deux

This is the second part of a series on trusts and the association rules. The first part appeared in the May 2026 issue of Canadian Tax Focus. The second part addresses how the rules can apply. Divorced Spouses Divorced spouses…

Continue reading…

Deductibility of professional fees

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…

Continue reading…

TFSA advantage “tax” is a-ok

I just wrote about TFSA over-contribution hell. The Federal Court of Appeal recently confirmed that the advantage “tax” is constitutional under section 53 of the Constitution Act, 1867 and that no due-diligence defence is available because it is a tax.…

Continue reading…

Part VI.1 tax

The Part VI.1 tax rules, which date from the late 1980s, can apply in unexpected and unhelpful ways to transactions that have nothing to do with the harm at which the rules were aimed. (The Department of Finance, in other…

Continue reading…

GLGI appeals struck

In a previous post, I discussed Kelly v R, 2026 TCC 53, in which Mr Justice Graham proposed to dismiss ongoing GLGI appeals as an abuse of process. Eight of the appellants to whom this proposal applied provided submissions for…

Continue reading…

Trusts and Association, Part Deux

This is the second part of a series on trusts and the association rules. The first part appeared in the May 2026 issue of Canadian Tax Focus. The second part addresses how the rules can apply. Divorced Spouses Divorced spouses…

Continue reading…