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Category: Pipelines

2024 STEP Roundtable

Posted on: September 14, 2024 Last updated on: September 14, 2024 Written by: John Loukidelis
The following is based on the text published in Tax Topics 2713 (September 10, 2024). Question 1 – Spousal Trusts A spousal trust that receives a contribution of capital after the death of the spouse-beneficiary remains a spousal trust, but…
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Pipeline gotcha

Posted on: June 3, 2022 Last updated on: June 3, 2022 Written by: John Loukidelis
Clause 256(7)(a)(i)(D) provides that control of a corporation is not acquired only because a particular person who acquired the shares from an estate that arose on and as a consequence of the death of an individual, if the estate acquired…
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Post mortem pipeline gone wrong

Posted on: May 7, 2022 Last updated on: May 4, 2022 Written by: John Loukidelis
In Robillard (Succession) c R, 2022 CCI 13, an estate completed a pipeline for a corporation within seven months of the death of its shareholder. The CRA applied 84(2) to the pipeline. The taxpayer appealed. The Court, after criticizing Canada…
Continue reading “Post mortem pipeline gone wrong”…

84(2) catches a hybrid transaction

Posted on: October 27, 2021 Last updated on: November 3, 2021 Written by: John Loukidelis
In Foix c R, 2021 CCI 52, W4N sold its key business assets to EMC, an American corporation. Before and after the asset sale, the shareholders of W4N sold its shares (directly and indirectly) to a Canadian subsidiary of EMC…
Continue reading “84(2) catches a hybrid transaction”…

Pipeline Update

Posted on: August 5, 2020 Last updated on: October 2, 2020 Written by: John Loukidelis
The CRA usually requires that an estate wait for at least a year to receive repayments from the note issued by Newco as part of a pipeline, and the repayments that begin at that time must be spread out over…
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Pipeline and non-resident beneficiaries

Posted on: June 11, 2019 Last updated on: March 2, 2020 Written by: John Loukidelis
New paragraph 212.1(6)(b) deems Newco to have paid dividends to non-resident beneficiaries of an estate that is implementing a pipeline so that Newco must pay withholding tax. The change is effective from budget day, 2018, even though nothing in the…
Continue reading “Pipeline and non-resident beneficiaries”…

212.1 look-through and trusts

Posted on: April 11, 2019 Last updated on: February 20, 2011 Written by: John Loukidelis
Section 212.1 of the Income Tax Act (Canada) is an anti-avoidance rule that applies in circumstances similar to those for section 84.1. With section 212.1, however, only PUC (and not ACB) is relevant as far as the subject shares are…
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Pipeline and the 21-year rule

Posted on: April 11, 2019 Last updated on: April 11, 2019 Written by: John Loukidelis
The CRA has issued a pipeline ruling where the ACB of the shares being used to extract funds from a corporation is derived from a deemed disposition pursuant to the 21-year rule. Eric Hamelin, “Pipeline Transactions and the 21-Year Rule”,…
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Pipeline death watch?

Posted on: January 20, 2018 Last updated on: January 20, 2018 Written by: John Loukidelis
Finance is not proceeding with the July, 2017, proposals to amend 84.1 and introduce new 246.1. Also, Finance has said that it will focus on developing the passive income proposals. Finance has also said, however, that it believes post-mortem gains…
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VD Info Circular Updated

I just updated my webpage article on voluntary disclosures, which addresses the CRA’s amended policy on VDs found in IC00-1R7 (Voluntary Disclosures Program).
Continue reading “VD Info Circular Updated”…

Poker appeals dismissed

The taxpayers’ appeals in the poker winnings trilogy of cases have been dismissed: Fournier-Giguère v R, 2025 FCA 112. English translations of the Tax Court decisions are now available. See 2022 TCC 132 (Fournier‑Giguère Judgment), 2023 TCC 3 (D’Auteuil Judgment)…
Continue reading “Poker appeals dismissed”…

Twenty years

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”…

Shares acquired by a trust are QSBCSs

On January 1, 2023, a newly-formed personal trust purchased shares of Opco from Dad, who owned them throughout the preceding two years. The trust sold the shares on June 30, 2023, to an unrelated person. The CRA found that the…
Continue reading “Shares acquired by a trust are QSBCSs”…

TOSI and a power of attorney

Son is the owner of 10 out of 100 issued Common Shares in the capital of Opco, which are the only issued shares of the corporation. Son grants a power of attorney to his father to exercise all rights to…
Continue reading “TOSI and a power of attorney”…

Recent Posts

VD Info Circular Updated

I just updated my webpage article on voluntary disclosures, which addresses the CRA’s amended policy on VDs found in IC00-1R7 (Voluntary Disclosures Program).
Continue reading “VD Info Circular Updated”…

Poker appeals dismissed

The taxpayers’ appeals in the poker winnings trilogy of cases have been dismissed: Fournier-Giguère v R, 2025 FCA 112. English translations of the Tax Court decisions are now available. See 2022 TCC 132 (Fournier‑Giguère Judgment), 2023 TCC 3 (D’Auteuil Judgment)…
Continue reading “Poker appeals dismissed”…

Twenty years

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”…

Shares acquired by a trust are QSBCSs

On January 1, 2023, a newly-formed personal trust purchased shares of Opco from Dad, who owned them throughout the preceding two years. The trust sold the shares on June 30, 2023, to an unrelated person. The CRA found that the…
Continue reading “Shares acquired by a trust are QSBCSs”…

TOSI and a power of attorney

Son is the owner of 10 out of 100 issued Common Shares in the capital of Opco, which are the only issued shares of the corporation. Son grants a power of attorney to his father to exercise all rights to…
Continue reading “TOSI and a power of attorney”…

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Archives

Categories

Recent Posts

VD Info Circular Updated

I just updated my webpage article on voluntary disclosures, which addresses the CRA’s amended policy on VDs found in IC00-1R7 (Voluntary Disclosures Program).
Continue reading “VD Info Circular Updated”…

Poker appeals dismissed

The taxpayers’ appeals in the poker winnings trilogy of cases have been dismissed: Fournier-Giguère v R, 2025 FCA 112. English translations of the Tax Court decisions are now available. See 2022 TCC 132 (Fournier‑Giguère Judgment), 2023 TCC 3 (D’Auteuil Judgment)…
Continue reading “Poker appeals dismissed”…

Twenty years

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”…

Shares acquired by a trust are QSBCSs

On January 1, 2023, a newly-formed personal trust purchased shares of Opco from Dad, who owned them throughout the preceding two years. The trust sold the shares on June 30, 2023, to an unrelated person. The CRA found that the…
Continue reading “Shares acquired by a trust are QSBCSs”…

TOSI and a power of attorney

Son is the owner of 10 out of 100 issued Common Shares in the capital of Opco, which are the only issued shares of the corporation. Son grants a power of attorney to his father to exercise all rights to…
Continue reading “TOSI and a power of attorney”…

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