Archives - août 2016

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  Copeland v. R. - TCC: Taxpayer liable under subsection 160(1) for transfer from related corporation

  9 août 2016 By Bill Innes

  catégories:

  • Bill Innes on Current Tax Cases
  • Federal Income Tax
  • Personal Tax, Estate & Wealth Planning

  Précis: Mr. Copeland received cheques totally $111,000 from a related corporation, Tradepro, at a time when it was a tax debtor. As a result he was assessed under subsection 160(1) for the amount of tax debt of Tradepro at the date of the transfer. Mr. Copeland testified that the cheques were partial repayment of a loan made by his late father (who also used the same middle name, Blaine) to a predecessor corporation of Tradepro and that he held the funds as the agent of his father. Unfortunately for Mr. Copeland the Court did not accept his evidence or that of his bookkeeper and the appeal was dismissed with costs.
  Copeland v. R. - TCC: Taxpayer liable under subsection 160(1) for transfer from related corporationPlus >
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  Klundert v. R. - TCC: Payments to wife of tax debtor physician subject to subsection 160(1)

  3 août 2016 By Bill Innes

  catégories:

  • Bill Innes on Current Tax Cases
  • Federal Income Tax
  • Personal Tax, Estate & Wealth Planning

  Précis: This may be one of the last chapters of the Klundert litigation about a tax protesting doctor. In this case roughly $1,000,000 had been transferred at Dr. Klundert’s direction by OHIP to his wife’s account during a period when he was a tax debtor. CRA assessed Mrs. Klundert under subsection 160(1) in respect of the transfer. The Tax Court rejected the appeal with the exception of a small ($3,614.51) adjustment. Somewhat unusually, there was no order as to costs.
  Klundert v. R. - TCC: Payments to wife of tax debtor physician subject to subsection 160(1)Plus >