Tax Alert Archives May 2015

Pallen Trust: dividend payment rescinded due to a mistake as to the tax consequences

In Re Pallen Trust, 2015 BCCA 222, a corporation paid a dividend to a discretionary trust on the assumption that subsection 75(2) of the Income Tax Act would attribute the income to the corporation. At the time, the general understanding

Prepared by: Jennifer Flood

Jennifer Flood is an associate practicing in the firm’s Vancouver office. Jennifer’s practice focuses on taxpayer representation and tax litigation (including civil and criminal matters), and also includes personal and corporate tax planning. Prior to joining Thorsteinssons, she worked as… more »

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New CRA Income Tax Folio on Partnerships

The CRA cancelled IT-90 and released a new Income Tax Folio outlining the factors relevant to determining whether a partnership exists: “What is a partnership?” (S4-F16-C1). Comments from the public will be accepted until August 5, 2015.

 

Prepared by: Jennifer Flood

Jennifer Flood is an associate practicing in the firm’s Vancouver office. Jennifer’s practice focuses on taxpayer representation and tax litigation (including civil and criminal matters), and also includes personal and corporate tax planning. Prior to joining Thorsteinssons, she worked as… more »

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Rectification rejected by Quebec Court of Appeal in Mac’s Convenience Stores

In Mac’s Convenience Stores Inc. v. Canada, 2015 QCCA 837, the Quebec Court of Appeal upheld the decision of the Superior Court refusing to allow rectification of a $136 million dividend that caused adverse tax consequences the company’s tax…

Prepared by: Jennifer Flood

Jennifer Flood is an associate practicing in the firm’s Vancouver office. Jennifer’s practice focuses on taxpayer representation and tax litigation (including civil and criminal matters), and also includes personal and corporate tax planning. Prior to joining Thorsteinssons, she worked as… more »

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Parliament passes Bill C-51, expanding the CRA’s power to share taxpayer information

Parliament has passed the government’s controversial Bill C-51, enacting the Security of Canada Information Sharing Act. A related amendment to subsections 241(9) and (10) of the Income Tax Act gives CRA officials the power to share taxpayer information with…

Prepared by: Jennifer Flood

Jennifer Flood is an associate practicing in the firm’s Vancouver office. Jennifer’s practice focuses on taxpayer representation and tax litigation (including civil and criminal matters), and also includes personal and corporate tax planning. Prior to joining Thorsteinssons, she worked as… more »

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New CRA Income Tax Folio on Interest Deductibility

The CRA released a compilation of its positions on interest deductibility under paragraph 20(1)(c) and other provisions in a new Income Tax Folio, “Interest Deductibility” (S3-F6-C1), which cancels IT-533. Comments from the public will be accepted until June 6,…

Prepared by: Jennifer Flood

Jennifer Flood is an associate practicing in the firm’s Vancouver office. Jennifer’s practice focuses on taxpayer representation and tax litigation (including civil and criminal matters), and also includes personal and corporate tax planning. Prior to joining Thorsteinssons, she worked as… more »

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