• Skip to main navigation
  • Skip to main content
  • Skip to footer
Loukidelis PC

Loukidelis PC

Effective. Accessible. Responsive

  • Services
  • About
  • LPC Notes
  • Articles
  • Privacy Policy
  • Contact Us
  • Disclaimer
  • Skip to menu toggle button

Category: Miscellaneous (page 6)

Income averaging?

Posted on: December 15, 2012 Last updated on: December 15, 2012 Written by: John Loukidelis

Mark Hunter pointed out to me that paragraph 20(1)(j) of the Income Tax Act (Canada) doesn’t work well as an income-averaging tool if used in circumstances where the person taking the loan can’t repay it any time soon or will do so in a year without much income.

Continue reading “Income averaging?”…

Audit process

Posted on: October 7, 2012 Last updated on: October 7, 2012 Written by: John Loukidelis
The next issue of the Hamilton Law Association Journal will contain an article I’ve written on the audit process and a taxpayer’s liability under the Income Tax Act.
Continue reading “Audit process”…

Checklists

Posted on: June 10, 2012 Last updated on: June 10, 2012 Written by: John Loukidelis
Some time ago, I read The Checklist Manifesto, and since then I’ve implemented a number of checklists in my practice. I’d like to do more of them because I find them so useful. The trick of course, is to find…
Continue reading “Checklists”…

More rectification cases

Posted on: March 30, 2012 Last updated on: March 30, 2012 Written by: John Loukidelis

Blaine Cameron at KPMG, Hamilton, was kind enough to point me in the direction of two recent rectification decisions.

Continue reading “More rectification cases”…

Learned Hand on Tax

Posted on: March 12, 2012 Last updated on: March 12, 2012 Written by: John Loukidelis
The eminent jurist Learned Hand on the 1939 Internal Revenue Code: In my own case the words of such an act as the income tax, for example, merely dance before my eyes in a meaningless procession: cross-reference to cross-reference, exception…
Continue reading “Learned Hand on Tax”…

Labow appeal dismissed

Posted on: February 26, 2012 Last updated on: February 26, 2012 Written by: John Loukidelis
The Federal Court of Appeal has dismissed the taxpayer’s appeal in Labow v R, 2011 FCA 305. The taxpayer had paid amounts to an offshore health and welfare trust for his wife`s benefit (she was an employee in his surgical…
Continue reading “Labow appeal dismissed”…

Quotes

Posted on: January 31, 2012 Last updated on: January 31, 2012 Written by: John Loukidelis
I’ve been quoted a couple of times recently in tax-related stories in The Lawyers Weekly, most recently in a story on Johnson v R, 2011 TCC 540, which I wrote about here.
Continue reading “Quotes”…

Freeze share values

Posted on: January 27, 2012 Last updated on: January 27, 2012 Written by: John Loukidelis

Bryan Walters has drawn my attention to an interesting CRA technical interpretation (2011-0404641C6 or CCH Window ¶10,832) in which the CRA states that the provisions of a shareholder agreement might reduce the value of freeze shares that otherwise have the “right” attributes for the purposes of a freeze (see “Freeze Shares“).

Continue reading “Freeze share values”…

Donation tax shelter class action

Posted on: December 13, 2011 Last updated on: December 13, 2011 Written by: John Loukidelis
For an article on donation tax shelter class actions, click here.
Continue reading “Donation tax shelter class action”…

The Arnold Report

Posted on: November 25, 2011 Last updated on: November 25, 2011 Written by: John Loukidelis
Brian Arnold maintains a blog of sorts over at the CTF website. I say “of sorts” not to denigrate what he does with his posts—which are always informative and often quite funny—but to point out that when you number your…
Continue reading “The Arnold Report”…
« Previous page 1 … 4 5 6 7 8 … 15 Next page »

Archives

Categories

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”…

Archives

Categories

Meta

  • Log in
  • Entries feed
  • Comments feed
  • WordPress.org

About this site

Click here for an important disclaimer about this site.

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”…

© Loukidelis Professional Corporation

imunify-bot-check