Case Comment: NRT Technology Corp. v. R. - Losses and Reasonable Expectation of Profit July 01, 2013 Barbara Mazur A recent decision of the Tax Court of Canada, NRT Technology Corp. v. R, confirms the use of the reasonable expectation of profit test in the context of subsection 111(5)of the Income Tax Act (Canada).
Socially Responsible Taxation: Smelling the Coffee July 01, 2013 Sabina Mexis, Pablo Caballero The recent release of millions of leaked records and thousands of names by the International Consortium of Investigative Journalists (ICIJ) exposed the millions of dollars secreted away in offshore tax havens.
Revise NRT Rules Expand Exemptions for Mutual Funds and Commercial Trusts March 01, 2013 Craig Webster, Stephanie Wong On November 21, 2012, Bill C-48, the,em> Technical Tax Amendments Act, 2012, received first reading in the House of Commons.
Case Comment: Noran West Developments Ltd. v. The Queen – Waiver of Rights Fatal to Tax Appeal March 01, 2013 Stevan Novoselac, John Sorensen The Tax Court of Canada's recent decision in Noran West Developments Ltd. v. The Queen, where the Court quashed the appeal because the appellant had waived its right to object or appeal from the reassessment in issue.
Important Elections Arising from 2012 Income Tax Legislation March 01, 2013 Richard W. Johnson John J. Tobin G. Leila Ross Last year was busy for tax professionals with the introduction of complex legislative proposals and the long awaited omnibus technical amendment bills.
Case Comment: Caruso v. R: Player’s Agent Fees Non-Deductible: Is it Time for a Change? March 01, 2013 John J. Tobin A recent decision from the Tax Court of Canada (the “Tax Court”) has affirmed the Canada Revenue Agency’s (“CRA”) position that player’s agent fees are non-deductible from a player’s salary.
Case Comment: The Queen v. Johnson: Investigating the Tax Treatment of Ponzi Schemes March 01, 2013 Shaira Nanji A Ponzi scheme can be described as a scheme where a fraudster “robs Peter to pay Paul.”
Case Comment: Guindon v. Her Majesty the Queen: Tax Advisors & Accountants’ Third-Party Penalties: Civil or Criminal? March 01, 2013 Peter Aprile Parliament recently decided to expand the legislation in s. 239 of the Income Tax Act to enable the CRA to punish tax advisors, promoters, planners and preparers.
The “Sign and Close” – Deemed Year End Rules October 01, 2012 Joan E. Jung The complexities of the deemed year end rules in the Income Tax Act were illustrated in a recent Technical Interpretation in which the CRA made some thought-provoking comments relating to a “sign and close” scenario.
Is Post Mortem Pipeline Planning On Life Support? October 01, 2012 Heather McGeorge Post mortem planning is any plan that can mitigate the amount of tax payable on the death of a taxpayer and in his or her estate.