Archives - mars 2016

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  William B. Huxham Inc. v. R. - TCC: Taxpayer denied ABIL - inadequate proof of debt

  3 mars 2016 By Bill Innes

  catégories:

  • Bill Innes on Current Tax Cases
  • Corporate Tax
  • Federal Income Tax

  Précis: The appellant corporation claimed allowable business investment losses in 2008 and a resulting loss carry forward in 2009:
  William B. Huxham Inc. v. R. - TCC: Taxpayer denied ABIL - inadequate proof of debtPlus >
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  R. v. Lee - FCA: FCA reverses Federal Court and issues compliance order - section 231.7

  3 mars 2016 By Bill Innes

  catégories:

  • Bill Innes on Current Tax Cases
  • Federal Income Tax
  • Personal Tax, Estate & Wealth Planning

  Précis: The Federal Court denied CRA’s application for a compliance order under section 231.7 of the Income Tax Act ( the “ITA”) in respect of a requirement for information issued to Mr. Lee on the basis that it was overbroad and vague. The Federal Court of Appeal set aside the decision of the Federal Court and issued the compliance order sought by CRA. CRA was awarded costs both in the Federal Court of Appeal and the Federal Court.
  R. v. Lee - FCA: FCA reverses Federal Court and issues compliance order - section 231.7Plus >
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  Genest v. The Queen - TCC: Section 160 assessment of remuneration allegedly paid to wife upheld

  2 mars 2016 By Bill Innes

  catégories:

  • Bill Innes on Current Tax Cases
  • Federal Income Tax
  • Personal Tax, Estate & Wealth Planning

  Précis: Ms. Genest was assessed under section 160 with amounts totaling $45,000 transferred to her by businesses controlled by her partner, Martin Tremblay, at a time when he had a substantial income tax liability:
  Genest v. The Queen - TCC: Section 160 assessment of remuneration allegedly paid to wife upheldPlus >
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  6051944 Canada Inc. v. R. - TCC: Taxpayer allowed GST ITCs on management fees

  2 mars 2016 By Bill Innes

  catégories:

  • Bill Innes on Current Tax Cases
  • Commodity Tax
  • Federal Income Tax

  Précis: The appellant claimed, and was denied, GST input tax credits (ITC’s) on management fees paid to related corporations. The appellant appealed the denial of ITCs to the Tax Court:
  6051944 Canada Inc. v. R. - TCC: Taxpayer allowed GST ITCs on management feesPlus >
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  Raymond v. R. - TCC: Gross negligence penalties affirmed

  1 mars 2016 By Bill Innes

  catégories:

  • Bill Innes on Current Tax Cases
  • Federal Income Tax
  • Personal Tax, Estate & Wealth Planning

  Précis: Ms. Raymond and her spouse, Mr. Ludlow, operated a variety of businesses as well as a partnership. They were each assessed gross negligence penalties with respect to under-reported income in 2006 and 2007. The partnership was also assessed gross negligence penalties in respect of over-stated GST input tax credits during the same period. The Court affirmed the imposition of the penalties.
  Raymond v. R. - TCC: Gross negligence penalties affirmedPlus >
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  Lalande v. R. - TCC: Husband working for wife’s company denied EI benefits

  1 mars 2016 By Bill Innes

  catégories:

  • Bill Innes on Current Tax Cases
  • Employment Insurance/CPP
  • Federal Income Tax

  Précis: Mr. Lalande worked for a corporation controlled by his wife. When his employment was terminated on May 2, 2014 he applied for EI benefits. The benefits were denied on the basis that he was not engaged in insurable employment since the terms and conditions of his employment were not similar to arm’s length employment. He appealed to the Tax Court. The Tax Court concluded that the terms of his employment were not arm’s length and dismissed the appeal.
  Lalande v. R. - TCC: Husband working for wife’s company denied EI benefitsPlus >
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  Complimentary Tax Event in Toronto | Cross Border Tax Problems: Advising the Delinquent Filer

  1 mars 2016 By Taxnet Pro

  catégories:

  • International Tax

  Please join us for an evening of stimulating professional development with three Thomson Reuters Tax & Accounting Canada authors David W. Chodikoff, Dr. David Kerzner, and Max Reed.
  Complimentary Tax Event in Toronto | Cross Border Tax Problems: Advising the Delinquent FilerPlus >