Newbies to Ninja: Corporate Tax, 3rd Edition is now open for registration!

Newbies to Ninjas: Tax courses are targeted to improve efficiency and accuracy of newer preparers completing Personal Tax Returns or Corporate Tax Returns for Owner-Managed and Small Businesses.

These concise online 2.5-hour topic-by-topic course will have your newer tax preparers preparing Personal or Corporate Tax Returns like ninjas!

TOPICS INCLUDE:

  • T2 Identification and Information
  • Net Income and Taxable Income
  • Capital Assets
  • Investments
  • Small Business Deduction and associated issues
  • Dividends Paid and Received
  • Corporate Losses
  • Shareholder Activity
  • Donations, Internet Business Activities, T1135
  • CRA Services/Support

Tax Update 2017 - Now open for registration! LIVE in 17 cities.

Protect your clients and yourself; be aware of 2017 planning strategies and pitfalls. Tax Update 2017 – Fresh Ideas and New Snags, is the 33rd annual installment of the most current tax information and Canada Revenue Agency policies.

This fast-paced and highly detailed course offers hundreds of practical insights and suggestions in a simple and straightforward manner. After many years of receiving top ratings, you can rest assured that this session is sure to offer you a strong and effective base for the upcoming season of planning and compliance.

Topics

Updates including (but not limited to): new small business deduction rules;  new real estate and principal residence tax rules; remuneration strategies for owner-managers; tax effective remuneration for employees; trust and estate planning rules; 2017 federal and provincial budget changes; planning in the new United States regime; CRA administrative changes and initiatives; divorce and family changes; buying and selling a business; charities and NPOs; employer/employee issues; United States & international initiatives; partnerships; GST/HST; SR&ED; and various personal tax credits and deductions.

Discover which date and location is right for you!

Loan to Limited Partner - CRA opines that could constitute a draw, and therefore reduce the Partner's ACB immediately.

A June 27, 2016 French Technical Interpretation (2016-0637341E5, Gagnon, Robert) examined whether a loan to a limited partner could constitute a draw.

In the case, the limited partnership had a limited partner (LP), entitled to 99% of the partnership’s profit, and a general partner (GP), entitled to 1% of the partnership’s profits. The partnership earned income evenly throughout the year. At the beginning of the year the LP’s ACB was nil. Quarterly, the LP took a loan from the partnership equal to ¼ of the partnership’s annual profits. At the beginning of the following year, the partnership distributed profits in the form of a promissory note. The note and the loan were then immediately set-off.

CRA opined that the loan to the LP could constitute a draw as the scope of Subparagraph 53(2)(c)(v) is very broad. A review of the partnership agreement would be required to determine whether the draw was “on account or in lieu of… partnership profits.” If, the loan did constitute a draw, the ACB would be reduced immediately. As, in this case, the ACB at the start of the year was nil, a reduction would bring the ACB into a negative position, and, therefore, Subsection 40(3.1) would apply to deem the LP to realize a capital gain.

CRA also opined that there is a question as to whether a partner could in fact “loan” money from the partnership as a partnership is not a legal entity in and of itself.

For further information see Video Tax News Monthly Tax Update Newsletter, Issue No. 426

CRA - Sale of franchise - Could right to locate a purchaser for a departing partial owner cause association issues?

In an October 7, 2016 French Technical Interpretation (2016-0652971C6, Gladu, Guylaine), CRA addressed the impact of clauses in shareholders’ agreements (SA) in a franchise arrangement. Each franchise is held in a corporation owned equally by the franchisor and the manager of the franchise. Where the manager ceases employment, the SA would provide for the franchisor to arrange a sale of the manager’s shares to a third party, who cannot be the franchisor or an associate of the franchisor. 

CRA confirmed that the proposed right to locate a purchaser for the manager’s shares would not be considered a right for the franchisor to acquire the shares. Similarly, an automatic redemption would not be considered a right of the franchisor to force a redemption provided that the franchisor cannot control the event that would cause the redemption. As such, the proposed clauses would not cause the corporations to become associated or related.

For further information see Video Tax News Monthly Tax Update Newsletter, Issue No. 428