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Category: Miscellaneous (page 13)

A useful tool

Posted on: February 17, 2007 Last updated on: February 17, 2007 Written by: John Loukidelis

The Web contains many useful tools for lawyers such as the website of the Canadian Legal Information Institute (CanLII), which provides access to a wealth of statutes and cases. The Web has many other useful tools of course.

Continue reading “A useful tool”…

Damage control

Posted on: January 30, 2007 Last updated on: January 30, 2007 Written by: John Loukidelis
The Minister of Finance tries to explain his position on income trusts and the problems created by his announcement on Halloween, 2006.
Continue reading “Damage control”…

PC trouble

Posted on: January 20, 2007 Last updated on: January 20, 2007 Written by: John Loukidelis
In Morisset c. La Reine, 2006 CCI 483 (French only), the CRA reassessed the taxpayer to include in his income amounts supposedly earned by his “professional corporation”. The taxpayer, at law, was not permitted to share the revenue derived from…
Continue reading “PC trouble”…

Fraud, again

Posted on: January 11, 2007 Last updated on: January 11, 2007 Written by: John Loukidelis
It appears that even the Department of Finance is having to wage war on phishing: see E-mail Fraud Alert.
Continue reading “Fraud, again”…

Information for individuals leaving Canada

Posted on: January 5, 2007 Last updated on: January 5, 2007 Written by: John Loukidelis
From time to time my clients contemplate leaving Canada for warmer weather or more friendly tax collectors. Over the years, I have collected a set of CRA publications and forms that provide useful guidance on the tax consequences of becoming…
Continue reading “Information for individuals leaving Canada”…

Draft legislation for Christmas

Posted on: December 22, 2006 Last updated on: December 22, 2006 Written by: John Loukidelis
The Department of Finance generally gives tax practitioners a little something—obscure draft legislation usually—to chew on between Christmas and New Year’s. I was beginning to worry that the Department had forgotten about us this year, but I should have known…
Continue reading “Draft legislation for Christmas”…

The night before Christmas

Posted on: December 21, 2006 Last updated on: December 21, 2006 Written by: John Loukidelis

The following mentions tax, and so I think it is legitimate content for this blog.

May I say that we lawyers deserve the satire aimed at us by this poem.

Continue reading “The night before Christmas”…

New blogs

Posted on: December 16, 2006 Last updated on: December 16, 2006 Written by: John Loukidelis
Our firm is in the process of rolling out several new blogs. One of them is about trusts and estates. Cathy Olsiak and I have just posted an article to the blog about donating securities through a will.
Continue reading “New blogs”…

Ontario simplifies

Posted on: December 13, 2006 Last updated on: December 13, 2006 Written by: John Loukidelis
You have all read that the Ontario government plans to turn over the administration of its corporate income tax regime to the CRA. The government introduced draft legislation today to make that a reality. Now, when will the government muster…
Continue reading “Ontario simplifies”…

Criminal Charges

Posted on: November 16, 2006 Last updated on: November 16, 2006 Written by: John Loukidelis
It appears that over the last few years the Ontario Ministry of Finance has been getting tough with the directors of corporations who fail to file Ontario corporate tax returns. Failing to file such a return is a criminal offence,…
Continue reading “Criminal Charges”…
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Recent notes

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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