Author: Vivian Esper

Issues arising on the conversion of real property from capital to inventory (or vice versa)

Published by Vivian Esper

When a real property held by a taxpayer as a rental property becomes the taxpayer’s residence (or vice versa), the “change-in-use” rules in section 45 and subsection 13(7) of the Income Tax Act (the “ITA”) are triggered. Subsection 45(1) provides…

Tax Court finds that deposits into a joint bank account do not in and of itself constitute transfers of property for third-party liability assessments

Published by Vivian Esper

In White v The Queen[1], the Tax Court allowed Mrs. White’s appeal, holding that the deposits of funds by Mr. White, a “tax debtor”, into a joint bank account held by him and Mrs. White (the “Joint Bank Account”) did…