Photo by Rafael Minguet Delgado The taxpayer in Amicarelli v. The King was a full-time employee. In 2017, after hearing from people she knew that they had made hundreds of thousands of dollars from investing in bitcoins, she decided to make the jump and open an account with QuadrigaCX, a Canadian cryptocurrency exchange. In order […]
Losses Carryover / Report des pertes
Trust Prevented from Going Back on Its CCA Filing
The St. Benedict Catholic Secondary School Trust (the “Trust”) had a leasehold interest in the school bearing its name and surrounding land (class 13 property). From 1997 to 2003, the Trust claimed CCA and triggered non-capital losses (“NCLs”).
The Evolution of Control: De Jure, De Facto, and Now “Actual” Control (Under GAAR)
This judgment deals with GAAR. The Federal Court of Appeal reversed the decision of the Tax Court of Canada which had previously allowed the appeal by Deans Knight Income Corporation (“Forbes”) on the basis that GAAR did not apply.