Tax Issues

Total 356 Posts

Gift of Ecologically Sensitive Lands and the Carryover period for charitable donation deduction

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In Yellow Point Lodge Ltd. v, The Queen DTC 1130, the Company owned certain lands on Vancouver Island, mostly undeveloped and in its natural state. In June 2008, the Company granted a covenant and other specified legal interests with respect to a parcel of ecologically-sensitive land, to two organizations, with estimated fair market value in excess of $5 million. Initially, the Company did not claim a deduction in respect of….

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Canada Revenue Agency, Estate Administration, Estate Donations, Estate Planning, Real Estate, Tax Issues, Uncategorized, Wills

Attribution under 75(2)

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Income attribution rules, generally speaking, operate so that income of one person (the actual recipient of the income) is attributed to and becomes income of another person (the transferor). Whether or not income which is subject to subsection 75(2) is first and foremost income of the trust itself can be significant for how the trust return is prepared and/or whether or not a liability for alternative minimum tax. When questioned,….

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Canada Revenue Agency, Estate Administration, Estate Planning, Executors, Tax Issues

Inclusion of Life Insurance loan in Income

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In Neszt v. The Queen 2019 DTC 1105, the taxpayer held two life insurance policies with a life insurance company. He subsequently took personal loans against his life insurance policies. The amount of each such loan was greater than the adjusted cost base of each policy, (being the sum of premiums paid by the insured minus dividends declared and cost of insurance.) The life insurance company issued two T5 slips….

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Canada Revenue Agency, Insurance, Loans, Tax Issues, Uncategorized

The perils of home purchase loans

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Executors and personal representatives are tasked with making sure the deceased’s tax obligations are properly dealt with out of the deceased’s estate. An issue that may arise in the course of dealing with the obligations is how to deal with loans and advances from a private company. The Canada Revenue Agency (CRA) recently shared its view on the application of a tax rule to a home purchase loan from a private….

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Canada Revenue Agency, Estate Planning, Executors, Tax Issues

Celebrity Estates – Not Immune from the Trials and Tribulations of Estate Planning and Litigation

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With TIFF in full swing, celebrity worship is in overdrive. However, celebrities also deal with the mundane and there is often nothing glamorous about their estates. In fact, like the rest of us mere mortals, celebrities do not have a lock on getting things right. So often, there is so much money sloshing around, coupled with the absence of a properly drawn will, that estate fights are inevitable. Michael Jackson’s….

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Contested wills, Estate Administration, Estate Administration and Probate Applications, Estate Litigation, Estate Planning, Executors, Family Conflict, Fiduciary Professions, Interest, International, Succession Planning, Tax Issues, U.S. Citizen, United States, US Taxes, Wills

DEEMED TRUST: TAX DEBTS AND PROCEEDS OF INSURANCE

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In Canada (A.G.) v Nortip Development 2019 NLCA 34, a company fell behind in remitting payroll withholdings and related amounts for several periods over a two-year period to the Canada Revenue Agency (“CRA”). Around the same time, a property with a mortgage owned by the same company, was destroyed by fire. A portion of proceeds of insurance on that property (equal to the amount owed to the CRA) were claimed….

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Canada Revenue Agency, Property, Real Estate, Small Business, Tax Issues, Trusts, Uncategorized
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