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Category: Miscellaneous

Transfer of property

Posted on: February 13, 2026 Last updated on: February 13, 2026 Written by: John Loukidelis
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”…

Twenty years

Posted on: August 22, 2025 Last updated on: August 14, 2025 Written by: John Loukidelis
Today is the 20th anniversary of this blog. I made my first post on it on August 22, 2005. I’m now working on post number 1,077.
Continue reading “Twenty years”…

Canada Child Benefit and Shared Custody

Posted on: June 23, 2025 Last updated on: June 19, 2025 Written by: John Loukidelis
In Wong v R, 2025 TCC 24 (informal procedure), Mr Justice Bocock provided a helpful road map of the surprisingly complicated rules relating to shared custody and entitlement to the Canada Child Benefit.
Continue reading “Canada Child Benefit and Shared Custody”…

Post Number 1,000

Posted on: November 27, 2023 Last updated on: November 27, 2023 Written by: John Loukidelis
This post is number 1,000 in this, my blog about Canadian income tax law. I have been writing here more or less regularly, since August, 2005. I started writing the blog as a way of informing clients about recent developments…
Continue reading “Post Number 1,000”…

UHT Traps

Posted on: November 10, 2022 Last updated on: November 7, 2022 Written by: John Loukidelis
It appears that the underused housing tax (UHT) might apply to residential property owned by a partnership one of the partners of which is another partnership a trust where one or more of the beneficiaries of the trust is another…
Continue reading “UHT Traps”…

Underused Housing Tax Act

Posted on: May 4, 2022 Last updated on: May 4, 2022 Written by: John Loukidelis
Bill C-8 will enact the Underused Housing Tax Act (the “UHT Act”). The UHT Act will impose an annual tax equal to 1% of the value of certain residential properties. There are steep penalties for failing to file the associated…
Continue reading “Underused Housing Tax Act”…

Betrayed by fonts

Posted on: February 2, 2022 Last updated on: February 2, 2022 Written by: John Loukidelis
This story warmed my font-nerd heart. A bankruptcy trustee hired an expert in typography and design who testified that a document supposedly created in 1995 used fonts that weren’t available to the public until 2007. *Sad trombone sound*.
Continue reading “Betrayed by fonts”…

We have moved!

Posted on: August 5, 2020 Last updated on: December 10, 2020 Written by: John Loukidelis
We have moved! We are still at 20 Hughson St S in Hamilton, but our new suite number is 707. All of our other contact details remain the same. Our updated contact information can be found here. Because of COVID-19,…
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COVID-19 update

Posted on: July 3, 2020 Last updated on: October 2, 2020 Written by: John Loukidelis
Our office remains closed for now even as the province re-opens after the pandemic. We continue to serve our clients, however, by phone and by email. Our contact information can be found here.
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Hiatus

Posted on: June 29, 2020 Last updated on: October 2, 2020 Written by: John Loukidelis
I haven’t posted since May 20, 2020, which represents one of the longest (if not the longest) stretches I’ve gone without adding content to this site. My site was hacked, and so it has taken me a while a to…
Continue reading “Hiatus”…
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The sibling butterfly exception

The CRA has clarified that the subparagraph 55(5)(e)(i) exception for siblings will apply where the shares of either the distributing corporation (DC) or the transferee corporation (TC) (not both) need be quaified small business corporation shares or shares of a…
Continue reading “The sibling butterfly exception”…

Objections for large corporations

A corporation is a “large corporation” if its taxable capital, and that of any related corporation, employed in Canada exceeds $10 million (a limit that has not changed since it was set in 2006). Per subsection 165(1.11), a large corporation…
Continue reading “Objections for large corporations”…

Pleading away privilege

In One York Street Inc. v 2360083 Ontario Limited, 2026 ONCA 176, the Court held that, by putting in issue its state of mind on signing a lease where the state of mind was based in part on legal advice,…
Continue reading “Pleading away privilege”…

Resigning as a director

According to the author, Stevens v R, 2026 TCC 76, is an important reminder of the importance of “objective” evidence for a director’s resignation. Having a resignation witnessed, ensuring that the corporation has updated its records and ensuring that the…
Continue reading “Resigning as a director”…

Build Canada announcements

Oslers has a couple of good posts on its website—here and here—about tax-related “Canada strong” announcements. The CRA, when considering advance tax rulings, will prioritize “nation-building projects”, and the Income Tax Act (Canada) will be amended to permit a new…
Continue reading “Build Canada announcements”…

Recent Posts

The sibling butterfly exception

The CRA has clarified that the subparagraph 55(5)(e)(i) exception for siblings will apply where the shares of either the distributing corporation (DC) or the transferee corporation (TC) (not both) need be quaified small business corporation shares or shares of a…
Continue reading “The sibling butterfly exception”…

Objections for large corporations

A corporation is a “large corporation” if its taxable capital, and that of any related corporation, employed in Canada exceeds $10 million (a limit that has not changed since it was set in 2006). Per subsection 165(1.11), a large corporation…
Continue reading “Objections for large corporations”…

Pleading away privilege

In One York Street Inc. v 2360083 Ontario Limited, 2026 ONCA 176, the Court held that, by putting in issue its state of mind on signing a lease where the state of mind was based in part on legal advice,…
Continue reading “Pleading away privilege”…

Resigning as a director

According to the author, Stevens v R, 2026 TCC 76, is an important reminder of the importance of “objective” evidence for a director’s resignation. Having a resignation witnessed, ensuring that the corporation has updated its records and ensuring that the…
Continue reading “Resigning as a director”…

Build Canada announcements

Oslers has a couple of good posts on its website—here and here—about tax-related “Canada strong” announcements. The CRA, when considering advance tax rulings, will prioritize “nation-building projects”, and the Income Tax Act (Canada) will be amended to permit a new…
Continue reading “Build Canada announcements”…

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Archives

Categories

Recent Posts

The sibling butterfly exception

The CRA has clarified that the subparagraph 55(5)(e)(i) exception for siblings will apply where the shares of either the distributing corporation (DC) or the transferee corporation (TC) (not both) need be quaified small business corporation shares or shares of a…
Continue reading “The sibling butterfly exception”…

Objections for large corporations

A corporation is a “large corporation” if its taxable capital, and that of any related corporation, employed in Canada exceeds $10 million (a limit that has not changed since it was set in 2006). Per subsection 165(1.11), a large corporation…
Continue reading “Objections for large corporations”…

Pleading away privilege

In One York Street Inc. v 2360083 Ontario Limited, 2026 ONCA 176, the Court held that, by putting in issue its state of mind on signing a lease where the state of mind was based in part on legal advice,…
Continue reading “Pleading away privilege”…

Resigning as a director

According to the author, Stevens v R, 2026 TCC 76, is an important reminder of the importance of “objective” evidence for a director’s resignation. Having a resignation witnessed, ensuring that the corporation has updated its records and ensuring that the…
Continue reading “Resigning as a director”…

Build Canada announcements

Oslers has a couple of good posts on its website—here and here—about tax-related “Canada strong” announcements. The CRA, when considering advance tax rulings, will prioritize “nation-building projects”, and the Income Tax Act (Canada) will be amended to permit a new…
Continue reading “Build Canada announcements”…

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