On July 16, 2010, the Department of Finance released a significant package of income tax technical amendments and explanatory notes.  As I am writing this blog, I have a binder of material in front of me that contains all of the material released by the Department of Finance and it is approximately 2 ½ inches thick.  Oh joy!  Great summer time reading!!

In all seriousness, though, this material is very welcome news given that it contains significant provisions some of which have been outstanding for approximately 8 years.  Let’s hope this package gets passed into law soon.

One of the significant amendments included in the income tax technical package are the restrictive covenant proposals.  Such provisions are horrifically complex.  Our firm wrote a paper on the restrictive covenant draft proposals in 2008.  For those interested in an exercise in complexity, feel free to read the paper.  Such provisions are wide sweeping and will change how most purchase and sale agreements are handled from a taxation perspective.  For further information, take a look at our blog of April 10, 2008.

In an episode of Corner Gas, the main character, Brent, (who is single, has no children and is 40 years old) finds himself overwhelmed by a hot-wheels-tossing 6 year old boy and besieged under a kitchen table while babysitting for a friend.  Brent enlists the help of his mother, Emma, who quickly gains control of the situation and explains her two-pronged philosophy for disciplining kids:

Wow, time flies when you're having fun ....!

May and June are conference months with our firm recently speaking at the STEP Pacific Rim Conference and the Canadian Association of Gift Planners Conference in Edmonton. Our firm will also soon be speaking at the Canadian Tax Foundation Prairie Provinces Conference and the STEP National Conference.  Certainly no shortage of activity.

First off, what an Olympics!  As a proud Canadian, yesterday will certainly go down in the memory banks as one of the most significant days in Canadian sports history.  Vancouver did an amazing job hosting the Olympics and did Canada proud.  Of course, many of us were interested in the Canadian men's hockey team result and watching the game was a "pins and needles" exercise but when Sidney Crosby scored the overtime goal what a rush of excitement!  Oh Canada!!

In the recent decision of Collins v. The Queen, the Federal Court of Appeal clarifies the meaning of "an amount payable in respect of the year" - one of the requirements for interest deductibility under paragraph 20(1)(c) of the Income Tax Act (the "Act").  Specifically, in order for interest to be deductible under paragraph 20(1)(c) of the Act, there must be: 

The Federal Court of Appeal has recently confirmed that a taxpayer and a company controlled by the taxpayer's nephew are considered to "act at arm's length" in a transaction where the nephew's company purchases promissory notes from a charity controlled by the taxpayer only to help the taxpayer solve a tax problem.