Tax Notes

Digital pen making contact with line graph on screen

July 2014

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Rectification: Current Developments Regarding This Useful Judicial Remedy

Lesley M. Akst

Rectification is an equitable remedy that allows for judicial corrections of a document that, due to errors in drafting, does not reflect the true intentions of the parties. Rectification changes a document’s mistaken expression of that intention. Rectification is restorative,...


“Half-loaf” Gone Wrong: Gervais, G. et al. v. The Queen (“Gervais”).

Bryant D. Frydberg

A recent case from the Tax Court of Canada ruled against a taxpayer who implemented a tax plan known as the “half-loaf” plan.  The purpose of a half-loaf plan is essentially to multiply the life time capital gain exemption between...


Current Changes to Testamentary Trusts and Continuing Advantages

Andrea Lamy, William J. Fowlis

The 2014 Federal Budget proposes to introduce a number of significant changes to the taxation of trusts and estates which will fundamentally change the landscape of estate planning. The Department of Finance (the “Department”) proposed these changes to eliminate the...


Displaying 1-3 of 3