Recent Posts

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  Dhanoa v. R. - TCC: Court rejects due diligence defence on unreported income

  Jul 15, 2015 By Bill Innes

  Categories:

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

  Précis: Mr. Dhanoa failed to report investment income in both 2011 and 2012. As a consequence the Minister applied a 10% penalty under subsection 163(1) of the Income Tax Act (the “Act”) to his 2012 taxation year.
  Dhanoa v. R. - TCC: Court rejects due diligence defence on unreported incomeREAD MORE »
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  Langard v. R. - TCC: Taxpayer not entitled to losses generated by his holding corporation

  Jul 15, 2015 By Bill Innes

  Categories:

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

  Précis: Mr. Langard claimed business losses from trading in commodity futures in the amounts of $472,029.89 in 2006 and $151,551.06 in 2007. The trading occurred in an account of Bearsden Enterprises Ltd., (“Bearsden”); Mr. Langard was a director and president of Bearsden. The sole question before the Court was whether the losses were incurred by Mr. Langard or Bearsden.
  Langard v. R. - TCC: Taxpayer not entitled to losses generated by his holding corporationREAD MORE »
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  Carphin v. R. - TCC: Offshore commissions from selling Ponzi scheme taxable

  Jul 14, 2015 By Bill Innes

  Categories:

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

  Précis: Mr. Carphin earned considerable commission income between 2001 and 2006 selling investments through the Institute of Financial Learning an organization which proved to be a part of a traditional Ponzi scheme.
  Carphin v. R. - TCC: Offshore commissions from selling Ponzi scheme taxableREAD MORE »
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  Curry v. R. - TCC: Ex-husband paying child support not entitled to Tax Credits

  Jul 13, 2015 By Bill Innes

  Categories:

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

  Précis: The only point at issue in this appeal was whether Mr. Curry was entitled to “claim the tax credits for a Wholly Dependent Person and the Child Amount (the “Tax Credits”) with respect to his daughter in his 2011 and 2012 taxation years”.
  Curry v. R. - TCC: Ex-husband paying child support not entitled to Tax CreditsREAD MORE »
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  Berger v. R. - TCC: Sports blogger engaged in business, entitled to claim losses

  Jul 13, 2015 By Bill Innes

  Categories:

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

  Précis: Mr. Berger was a journalist who previously worked for FAN 590 radio covering hockey. As one part of his work he filed blogs.
  Berger v. R. - TCC: Sports blogger engaged in business, entitled to claim lossesREAD MORE »
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  GMAC Leaseco v. R. - TCC: $235 million “support payments” from GM taxable

  Jul 10, 2015 By Bill Innes

  Categories:

  • Bill Innes on Current Tax Cases
  • Corporate Tax
  • Federal Income Tax

  Précis: This decision involves four sources of income which were assessed by CRA against GMAC Leasco (“GMAC”) [para. 2 of the Reasons].
  GMAC Leaseco v. R. - TCC: $235 million “support payments” from GM taxableREAD MORE »
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  Delle Donne v. R. - TCC: CRA loses attempt to tax bad debt in Ponzi scheme

  Jul 08, 2015 By Bill Innes

  Categories:

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

  Précis: The appellant was a retired dentist who invested his funds at high rates of return with a corporation (“SA”) owned by his brother-in-law, Mr. Amato. That corporation in turn invested the funds with another corporation (“EMB”) controlled by an unrelated individual, Mr. Mander.
  Delle Donne v. R. - TCC: CRA loses attempt to tax bad debt in Ponzi schemeREAD MORE »
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  Coombs v. R. - TCC: Tax Court rejects alleged losses

  Jul 08, 2015 By Bill Innes

  Categories:

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

  
  Coombs v. R. - TCC: Tax Court rejects alleged lossesREAD MORE »
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  Lubega-Matovu v. R. - TCC: Court finds business losses fictitious

  Jul 07, 2015 By Bill Innes

  Categories:

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

  Précis: Mr. Lubega-Matovu was, at the date of the hearing, a retired senior auditor with CRA. In 2006, 2007 and 2008 he claimed business and rental losses that essentially reduced his taxable income to nothing. His wife, Ms. Lukwago, claimed a small amount of business income in those years and also claimed losses from businesses carried on with her husband.
  Lubega-Matovu v. R. - TCC: Court finds business losses fictitiousREAD MORE »
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  Naraine v. R. - TCC: Damage award against former employer largely taxable

  Jul 07, 2015 By Bill Innes

  Categories:

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

  Précis: Mr. Naraine was terminated by Ford in 1985. He spent 21 years pursuing a claim against Ford and was finally awarded a total of $369,422.82 consisting of general damages, special damages and pre- and post- judgment interest on both.
  Naraine v. R. - TCC: Damage award against former employer largely taxableREAD MORE »