In a July 22, 2015 Tax Court of Canada case (9259-9893 Quebec Inc. vs. H.M.Q., 2014-1352(GST)I), the taxpayer was unsuccessful in Appealing CRA’s GST assessment based on the taxpayer’s unreported business income. CRA examined the cash bank deposits to determine the unreported revenue.
For further information see VTN Monthly Tax Update Seminar, Issue No. 409
Watch Jeremy J. Herbert, MBA, LL.B of Felesky Flynn LLP discuss the Section 55 Changes.
Click here for the source documentation.
In a March 2, 2015 Technical Interpretation (2014-0527281E5, Dagenais, Anne), CRA clarified that even if the individual does not own or lease the property but is responsible for it and pays expenses on a regular basis, the location may be a SCDE. Where the payments are random or irregular, it will not be a SCDE.
For further information see VTN Monthly Tax Update Seminar, Issue No. 409
On July 10, 2015, CRA released Income Tax Folio S4-F2-C1: Deductibility of Fines and Penalties replacing Interpretation Bulletin IT-104R3. Among other matters, the Folio addresses Section 67.6 in detail, a provision which was only pending when the Interpretation Bulletin was last updated. That provision denies a deduction for any fine or penalty imposed under federal, provincial, municipal or foreign law, except for prescribed penalties. At present, the only prescribed penalty is a 1⁄2 of 1% per month penalty on duties, penalties and interest imposed under Paragraph 110.1(1)(a) of the Excise Tax Act.
CRA noted that “fine” and “penalty” are not defined terms, and the legislation imposing the charge would be expected to identify it as a fine or a penalty. CRA noted that Section 67.6 does not restrict deductions for penalties under private contracts, or interest charges on penalties, although other provisions could restrict their deductibility (such as Paragraph 18(1)(t) which prevents deduction of interest imposed under the Income Tax Act).
For further information see VTN Monthly Tax Update Seminar, Issue No. 409
In a June 18, 2015 National Post article (How to Keep Your Kids from Blowing the Family Fortune, Chris Taylor, Reuters), discussed were some rates of Family Estate losses from one generation to the next and strategies to preserve it.
The author interviewed some specialists and reviewed some surveys to note the following:
For further information see VTN Monthly Tax Update Seminar, Issue No. 408