Pierce Quaghebeur

Jun 17, 2024 | mondaq.com | Pierce Quaghebeur

It may not seem intuitive, but there are certain situations where it is possible for a creditor to recoup some of their lost loan from a non-arm's length debtor in the form of a capital loss or, if the debtor is a small business corporation, a business investment loss (for further information on allowable business investment losses, please read our Tax Notes series on ABIL Claims Part I and Part II). Is it a bad debt?

Jun 13, 2024 | lexology.com | Pierce Quaghebeur

It may not seem intuitive, but there are certain situations where it is possible for a creditor to recoup some of their lost loan from a non-arm’s length debtor in the form of a capital loss or, if the debtor is a small business corporation, a business investment loss (for further information on allowable business investment losses, please read our Tax Notes series on ABIL Claims Part I and Part II). Is it a bad debt?

Aug 10, 2023 | lexology.com | Andrew Bateman |Pierce Quaghebeur

Proactive planning to multiply access to the lifetime capital gains exemption (“LCGE”) for shares of a qualified small business corporation (“QSBC”) or qualified family farm property (“QFFP”) remains of ongoing interest to taxpayers and their family members that may be eligible to benefit. There is no apparent general opposition to such planning by the Canada Revenue Agency (“CRA”) where it is carefully implemented through a family trust.

Jun 12, 2023 | mondaq.com | Andrew Bateman |Pierce Quaghebeur

Prior to 2021, section 84.1 of the Income Tax Act ("Act") created a real impediment to a tax-efficient succession of a family business from one generation to the next, effectively penalizing a sale to a family member compared to an arm's length third party from a tax perspective.