The decision of the Tax Court in MacDonald earlier this year (2012 TCC 123) has prompted quite a lot of discussion among tax professionals. The case seems to take the debate about the legitimacy of dividend stripping to a new…
In one of his first decisions on the bench of the Tax Court of Canada, recent appointee Justice Randall Bocock wasted no time showing his teeth: see O’Dwyer v. The Queen, 2012 TCC 261.
On a motion by the Appellant…
A recent CRA technical interpretation on the allocation of safe income among several classes of shares got me musing about our sometimes schizophrenic approach to drafting income tax legislation. Most often the drafters attempt to anticipate every nuance that might…