FACTS Jobin owned shares in Groupe AST (assume FMV = $13 million and ACB = $nil). He received an offer for his shares from a third-party purchaser. To minimize his taxes, Jobin undertook the following steps. Jobin rolled his shares in Groupe AST – which had a fair market value of $13 million – on …
2763478 Canada Inc. v. Canada Summary Click here for our summary of this case. Court (s) Database Federal Court of Appeal Decisions Date 2018-11-15 Neutral citation 2018 FCA 209 File numbers A-243-17 CORAM: NOËL C.J. BOIVIN J.A. DE MONTIGNY J.A BETWEEN: 2763478 CANADA INC. Appellant and HER MAJESTY THE QUEEN Respondent Heard at Montréal , …
Gaudette v. The Queen [NOTE: TRANSLATED USING GOOGLE, MAY NOT BE FULLY ACCURATE] Database – Court (s) Judgments of the Tax Court of Canada Dated 2018-10-30 Neutral reference 2018 TCC 208 File number 2017-961 (IT) I Judges and Taxing Officers Real Favreau Topics Income Tax Act Folder: 2017-961 (IT) I ENTER : MARTHE GAUDETTE, appellant and …
Income Tax Folio S7-F1-C1, Split-receipting and Deemed Fair Market Value Series 7: Charities and Non-profit Organizations Folio 1: Charitable Gifts and Deductions Chapter 1: Split-receipting and Deemed Fair Market Value Summary The purpose of this Chapter is to provide the CRA’s views on the application of subsections 248(30) to (41), which include the rules commonly referred to …
Income Tax Folio S7-F1-C1, Split-receipting and Deemed Fair Market Value Read More »
Series 4: Businesses Folio 8: Losses Chapter 1: Business Investment Losses Summary A taxpayer’s business investment loss is basically a capital loss from a disposition of shares in, or a debt owing to the taxpayer by, a small business corporation (SBC) where the disposition is: to an arm’s-length person; or one to which subsection 50(1) applies. One-half of this loss …
Income Tax Folio S4-F8-C1, Business Investment Losses Read More »
Income Tax Folio S3-F2-C1, Capital Dividends Series 3: Property, Investments and Savings Plans Folio 2: Dividends Chapter 1: Capital Dividends Summary This Chapter discusses capital dividends and the capital dividend account (CDA). The CDA keeps track of various tax-freesurpluses accumulated by a private corporation. These surpluses may be distributed tax-free in the form of capital dividends to the …
International Financial Reporting Standards The purpose of this article is to provide guidance on how the requirement for publicly accountable enterprises (PAEs) to adopt International Financial Reporting Standards (IFRS), effective for interim and annual financial statements relating to fiscal years beginning on or after January 1, 2011, will affect those enterprises’ tax reporting. IFRS will …