In 2015-0594461E5, the CRA indicated that a taxpayer’s intention not to claim a capital gains exemption is irrelevant to the application of the ACB grind under subsection 84.1(2.1) of the Income Tax Act (Canada) which deems a taxpayer to…
Florence Sauve is a partner in the Toronto office of Thorsteinssons LLP.
Florence’s practice focuses on all aspects of taxpayer representation and tax. She assists her clients in managing and resolving tax audit and appeal disputes and represents her clients… more »
Paragraph 1.48 of Folio S3-F6-C1 provides that an interest expense on borrowed money used to redeem shares or return capital may be deductible if the borrowed money replaces capital previously used to earn income from a business or property.…
Florence Sauve is a partner in the Toronto office of Thorsteinssons LLP.
Florence’s practice focuses on all aspects of taxpayer representation and tax. She assists her clients in managing and resolving tax audit and appeal disputes and represents her clients… more »
In 2015-0572461I7, the CRA indicated that a Canadian resident individual who holds shares in disregarded LLCs through a Canadian LP and a US LP that has elected to be treated as a corporation for US tax purposes is entitled…
Florence Sauve is a partner in the Toronto office of Thorsteinssons LLP.
Florence’s practice focuses on all aspects of taxpayer representation and tax. She assists her clients in managing and resolving tax audit and appeal disputes and represents her clients… more »
Paragraph 60(o) of the Income Tax Act (Canada) allows a taxpayer to deduct professional fees “incurred in preparing, instituting or prosecuting an objection to, or an appeal in relation to, an assessment of tax […]”. The CRA recently confirmed that…
Florence Sauve is a partner in the Toronto office of Thorsteinssons LLP.
Florence’s practice focuses on all aspects of taxpayer representation and tax. She assists her clients in managing and resolving tax audit and appeal disputes and represents her clients… more »
