Recent Posts

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  Atlantic Thermal Star v. R. - TCC: Deductions for a bad debt and goodwill denied, costs denied

  Aug 02, 2016 By Bill Innes

  Categories:

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

  Précis: The taxpayer claimed a bad debt deduction in 2008 ($14,919) and a CEE deduction in 2010 ($4,996). It also claimed costs on the basis of alleged delay by the Minister. The taxpayer’s principal (Mr. Backman) did not testify; its case was put in entirely by its accountant. The Court rejected the appeal essentially on the basis that there was no evidence to demolish the Minister’s pleaded assumptions. Moreover there was no order as to costs (this was an informal procedure appeal).
  Atlantic Thermal Star v. R. - TCC: Deductions for a bad debt and goodwill denied, costs deniedREAD MORE »
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  Fisher v. R. - FCA: Taxpayer failed to establish debt was bad - appeal dismissed

  Dec 17, 2015 By Bill Innes

  Categories:

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

  Précis: This is a decision of the Federal Court of Appeal on appeal from a Tax Court decision blogged earlier on this site. The Tax Court Judge found that Ms. Fisher failed to establish that a debt owing to her was uncollectible by the end of 2004. The decision, which was rendered from the bench, found that the Tax Court Judge did not err in concluding that the taxpayer failed to establish the debt in question was bad.
  Fisher v. R. - FCA: Taxpayer failed to establish debt was bad - appeal dismissedREAD MORE »
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  Hill Fai Inv. v. R. - TCC: Inadequate evidence to demonstrate bad debt of $382,219.31 in 2006

  Jul 17, 2015 By Bill Innes

  Categories:

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

  Précis: The taxpayer claimed to have incurred a capital loss on a bad debt of $382,219.31 in its taxation year ended September 30, 2006. The loss in turn impacted on its taxation years ended September 30 in each of 2005, 2007 and 2008.
  Hill Fai Inv. v. R. - TCC: Inadequate evidence to demonstrate bad debt of $382,219.31 in 2006READ MORE »
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  Delle Donne v. R. - TCC: CRA loses attempt to tax bad debt in Ponzi scheme

  Jul 08, 2015 By Bill Innes

  Categories:

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

  Précis: The appellant was a retired dentist who invested his funds at high rates of return with a corporation (“SA”) owned by his brother-in-law, Mr. Amato. That corporation in turn invested the funds with another corporation (“EMB”) controlled by an unrelated individual, Mr. Mander.
  Delle Donne v. R. - TCC: CRA loses attempt to tax bad debt in Ponzi schemeREAD MORE »
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  Fisher v. R. – TCC: Taxpayer Did Not Prove Debt Had Become Bad

  Jul 24, 2013 By Bill Innes

  Categories:

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

  
  Fisher v. R. – TCC: Taxpayer Did Not Prove Debt Had Become BadREAD MORE »