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Category: Series of transactions

Series of transactions redux

Posted on: May 15, 2021 Last updated on: May 15, 2021 Written by: John Loukidelis
The author asks whether Agence du revenu du Québec c. Custeau, 2020 QCCA 1496, aff’g 2018 QCCQ 5692 (discussed here) reverses a trend that gave an expanded meaning to the phrase “series of transactions” in subsection 248(10) of the Income…
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Series of transactions

Posted on: April 10, 2021 Last updated on: April 16, 2021 Written by: John Loukidelis
In Agence du revenu du Québec c Custeau, 2020 QCCA 1496, the Court considered whether PUC shift and a subsequent reduction of that PUC were part of the same series of transactions such that the Quebec GAAR would apply to…
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Series of transactions

Posted on: November 14, 2020 Last updated on: November 14, 2020 Written by: John Loukidelis
It’s frustrating for clients when I tell them that about the “series of transactions” concept as it relates to related party butterflies. I tell them there’s no bright line test for what constitutes a series so that there is always…
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Timing of receipt of dividend on redemption

Under subsection 84(3) of the Income Tax Act (Canada) (the “Act”), where a corporation resident in Canada has redeemed, acquired or cancelled in any manner whatever … any of the shares of any class of its capital stock, (a) the…
Continue reading “Timing of receipt of dividend on redemption”…

GLGI appeals to be struck?

In Kelly v R, 2026 TCC 53, Justice Graham has given multiple taxpayers until April 24, 2026, to provide written submissions on why their appeals should not be struck without a hearing “for abusing this Court’s process”. The taxpayers were…
Continue reading “GLGI appeals to be struck?”…

Capital gain exemption fail

I wrote the following article for the Hamilton Law Association Journal on Ehresman v R, 2025 TCC 78. For another summary of the case, see Colin Bartlett “Are Excess Cash Reserves an Active Business Asset?” 25:4 Tax for the Owner-Manager…
Continue reading “Capital gain exemption fail”…

Relevant group entities

A relevant group entity (RGE) of a corporation (per subaparagraphs 84.1(2.31)(c)(iii) and 84.1(2.32)(c)(iii) in the intergenerational transfer (IGT) rules) is any entity carrying on an active business that is relevant to whether the corporation’s shares are qualified small business corporation…
Continue reading “Relevant group entities”…

IGT, de facto control and notes

The immediate transfer regime under the intergenerational transfer (IGT) rules found in subsection 84.1(2.31) will not provide a safe harbour from section 84.1, if the taxpayer-vendor at any time after the sale, either alone or with a spouse, has de…
Continue reading “IGT, de facto control and notes”…

Recent Posts

Timing of receipt of dividend on redemption

Under subsection 84(3) of the Income Tax Act (Canada) (the “Act”), where a corporation resident in Canada has redeemed, acquired or cancelled in any manner whatever … any of the shares of any class of its capital stock, (a) the…
Continue reading “Timing of receipt of dividend on redemption”…

GLGI appeals to be struck?

In Kelly v R, 2026 TCC 53, Justice Graham has given multiple taxpayers until April 24, 2026, to provide written submissions on why their appeals should not be struck without a hearing “for abusing this Court’s process”. The taxpayers were…
Continue reading “GLGI appeals to be struck?”…

Capital gain exemption fail

I wrote the following article for the Hamilton Law Association Journal on Ehresman v R, 2025 TCC 78. For another summary of the case, see Colin Bartlett “Are Excess Cash Reserves an Active Business Asset?” 25:4 Tax for the Owner-Manager…
Continue reading “Capital gain exemption fail”…

Relevant group entities

A relevant group entity (RGE) of a corporation (per subaparagraphs 84.1(2.31)(c)(iii) and 84.1(2.32)(c)(iii) in the intergenerational transfer (IGT) rules) is any entity carrying on an active business that is relevant to whether the corporation’s shares are qualified small business corporation…
Continue reading “Relevant group entities”…

IGT, de facto control and notes

The immediate transfer regime under the intergenerational transfer (IGT) rules found in subsection 84.1(2.31) will not provide a safe harbour from section 84.1, if the taxpayer-vendor at any time after the sale, either alone or with a spouse, has de…
Continue reading “IGT, de facto control and notes”…

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Archives

Categories

Recent Posts

Timing of receipt of dividend on redemption

Under subsection 84(3) of the Income Tax Act (Canada) (the “Act”), where a corporation resident in Canada has redeemed, acquired or cancelled in any manner whatever … any of the shares of any class of its capital stock, (a) the…
Continue reading “Timing of receipt of dividend on redemption”…

GLGI appeals to be struck?

In Kelly v R, 2026 TCC 53, Justice Graham has given multiple taxpayers until April 24, 2026, to provide written submissions on why their appeals should not be struck without a hearing “for abusing this Court’s process”. The taxpayers were…
Continue reading “GLGI appeals to be struck?”…

Capital gain exemption fail

I wrote the following article for the Hamilton Law Association Journal on Ehresman v R, 2025 TCC 78. For another summary of the case, see Colin Bartlett “Are Excess Cash Reserves an Active Business Asset?” 25:4 Tax for the Owner-Manager…
Continue reading “Capital gain exemption fail”…

Relevant group entities

A relevant group entity (RGE) of a corporation (per subaparagraphs 84.1(2.31)(c)(iii) and 84.1(2.32)(c)(iii) in the intergenerational transfer (IGT) rules) is any entity carrying on an active business that is relevant to whether the corporation’s shares are qualified small business corporation…
Continue reading “Relevant group entities”…

IGT, de facto control and notes

The immediate transfer regime under the intergenerational transfer (IGT) rules found in subsection 84.1(2.31) will not provide a safe harbour from section 84.1, if the taxpayer-vendor at any time after the sale, either alone or with a spouse, has de…
Continue reading “IGT, de facto control and notes”…

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