Please join David M. Piccolo & Vitaly Timokhov for our next installment:
In this webinar, David & Vitaly will discuss:
• Losses and Loss Determination Requests
• CRA Administrative Positions & Rulings of Interest
David Piccolo presents on loss determination requests, the products of such requests such as notices of determination or redetermination, the filing of notices of objection, mandamus requests to force the Minister to make a decision with respect to losses, the recharacterization of losses, select case law, statute-barred years, adjusting carry-forward balances, and limited partnership losses.
Vitaly Timokhov presents on trust attribution rules in subsection 75(2), family trusts, the applicability of the GAAR, dividend income, evil trusts designed to invoke subsection 75(2), compliance issues, subsection 74.1(1), holding capital interest in a personal trust, section 85 rollovers, capital property, and eligible property.