The court held that minor errors in the indictment and in the way the lower court estimated the total tax loss
Specifically, TEI believes the Canadian system for tax loss
utilization within corporate groups is far too restrictive, subject to significant administrative uncertainty, and imposes unnecessary costs on taxpayers seeking to avail themselves of CRA's administrative concessions.
Uninsured disaster victims can use the Federal Emergency Management Agency appraisal of their loss to document their tax loss
, a code section that was enacted after the Northridge earthquakes of 1994 [Sec.
That gave him a $3,000 tax loss
for the year and a $7,000 capital loss to carry forward, as well as cash in his pocket from selling those stocks."
But there usually is little or no tax loss
; instead, the loss is treated as an adjustment to ordinary income for tax purposes.
To be globally competitive, Canada should implement a formal Loss-Transfer System or otherwise provide for group tax loss
Although the Internal Revenue Service rejected the tax loss
claims, until recently the agency had been rebuffed in the courts, which concluded the exchanges resulted in realized losses--because the exchanged mortgages were materially different--and the realized losses were deductible because the statutory "wash sale" rules did not apply to mortgages.
Lois would then be given a $20,000 remedial tax loss
allocation t o reflect her share of the book loss.
Indeed, the Government must consider all aspects of the tax system as a whole and, in respect of tax loss
utilization for corporate groups, TEI regrets the Canadian system is too restrictive and subject to considerable administrative uncertainty.
Of 30 OECD countries surveyed in 2001, Canada was one of only four countries not to provide group tax loss
Of thirty OECD countries surveyed in 2001, Canada was one of only four countries that did not provide group tax loss
relief directly through its legislation.