Xref: utcsri bc.general:12498 can.general:41589 can.politics:63461 ont.general:22802 soc.culture.canada:57667 ut.general:7756 Newsgroups: can.general,can.politics,ont.general,ut.general,soc.culture.canada,bc.general Path: utcsri!info.physics.utoronto.ca!elrick From: elrick@helios.physics.utoronto.ca (Bruce Elrick) Subject: Negative Tax (was Re: Corporate taxes (was: ...)) Distribution: can Message-ID: Nntp-Posting-Host: helios.physics.utoronto.ca Sender: news@info.physics.utoronto.ca (System Administrator) Organization: University of Toronto - Dept. of Physics Date: Fri, 6 Jan 1995 17:07:53 GMT References: <1994Dec28.181321.26237@jarvis.cs.toronto.edu> <1995Jan2.183841.23307@jarvis.cs.toronto.edu> <3ei6g7$cik@ionews.io.org> <3eimo6$vjt@quartz.ucs.ualberta.ca> In article <3eimo6$vjt@quartz.ucs.ualberta.ca>, Timothy Huyer wrote: >Christopher B. Browne (cbbrown@io.org) wrote: > >: I think you've misunderstood the scheme slightly. The idea is to charge tax >: at a flat rate on the income above that arbitrary line. > >This is an excellent post -- my comliments! I have a couple things to >add, though: > >The proposal suggested by Christopher Browne is equivalent to the idea of >the Negative Income Tax, which had support from such lefty radicals as >Richard Nixon and Milton Friedman. In the simplest form, it would work >that each person would earn: > > a + t Y > [munch] > This does not suggest that all taxation, even all individual >(direct) taxation, should be put into a NIT scheme, nor does it suggest >that all transfers to individuals could be eliminated. Let's analyze the 'Negative Tax' in its simplest form. First, some definitions: ()_i is the value of some variable for person i ()_T is the sum over all people of ()_i, where i runs from 1 to P, the population G is the gross income N is the net income (after 'taxes') R is the revenue to the government, i.e. the net tax Clearly R_i = G_i - N_i. The simplest Negative tax is given by N_i = M + (1-r) G_i where M is the minimum net income and r is the tax rate. This means that net tax on an individual is R_i = G_i - N_i = G_i - M - (1-r) G_i = r G_i - M which can be negative. The question of whether such a tax is feasible is whether the government can generate enough revenue to operate, keeping in mind that perhaps we'll do away with welfare under this system but perhaps not Medicare, subsidized education, etc. The total government revenue is given by: R_T = sum_i R_i = sum_i (r G_i - M) = r (sum_i G_i) - M P = r G_T - M P G_T should be some (large?) fraction of the GDP, Gross Domestic Product. The average gross income per person is Gav = G_T/P so we can express the total government revenue as R_T = (r Gav - M) P What do we learn from this? We see that for the government have any revenue, the guaranteed minimum net income must be less than the tax rate times the average gross income. The National Product per capita is US$22200 (CIA World Fact Book, 1994 edition, data for year 1993) which is CA$31000. If we pick a rate r = 25% and assume that G_T = .66 GDP (I don't know what the fraction is), then we could support a minimum net income of M = 0.25 * 0.66 * 31000 ~= $5000, assuming the government does not need any revenue. If the fraction G_T/GDP is closer to 1 then M ~= $7500. Now let's relax our assumption that the government does not need revenue. The current federal expenditures are US$123 billion (ibid) so let's say we'll balance the federal budget. This is about $170 billion. Dividing by a population of 28 million (ibid) that gives us an average revenue Rav ~= $6000. This will make M negative for the 0.66 fraction G_T/GDP and make it $1500 for the 1.0 fraction. Go ahead an play with the numbers. Other things to note: M is for every person, including infants. The population of Canada is 28 million with a workforce of about 13 million (ibid). What is the crossover between being subsidized and paying, for an individual? Set N_i = G_i: G_i = M + (1-r) G_i ==> G_i = M/r Play with this parameter. Comments? Cheers... -- Bruce Elrick ---- Physics ---- University of Toronto ---- M5S 1A7 elrick@physics.utoronto.ca -- Office:MP1022 -- Phone:416-978-5207 From lloydl@the-wire.com Sun Mar 3 22:57:14 1996 Xref: elastic can.taxes:1666 Path: elastic!lethe!geac!gts!whome!infoshare!istar.net!news1.toronto.fonorola.net!news1.toronto.istar.net!news.toronto.istar.net!echo.the-wire.com!news From: lloydl@the-wire.com (Lloyd Lindsay) Newsgroups: can.taxes Subject: Re: Big check coming, how to avoid taxes. Date: Sun, 03 Mar 96 21:37:44 GMT Organization: Lloyd Lindsay - Chartered Accountant Lines: 76 Message-ID: NNTP-Posting-Host: lloydl.the-wire.com X-Newsreader: Quarterdeck Message Center [1.1] On Tues, Feb 27,96 Tasha Monaghan wrote: > Although such a sale to an offshore corporation would generate a taxable > gain, why couldn't this person sell the software to Offsore Inc. for > $X.00 and then have Offshore Inc sell the software to the end user for > $10X.00. Is this not similar to the approach that many companies use to > shelter part of their import/export revenues offshore? > WOW! Do you think you're the only one who has ever thought of this? Canada has tax legislation that would cost you a fortune if you did this. You have FOUR problems to deal with: Cross-border pricing, selling to a non-arm's length buyer at below market prices, GAAR (general anti-avoidance rules also known as the stink test), and non-disclosure rules. 1. CROSS-BORDER PRICING: ------------------------- Where Canada has a tax treaty with a country that has similar rates, your pricing must satisfy both countries' tax authorities. And sometimes you may wind up in a situation where the vendor pay tax on $X of sales while the purchaser can deduct only a smaller amount. 2. NON-ARM'S LENGTH SALES: -------------------------- Where you sell your goods to a company you own, the transaction would be a non-arm's length sale. And if the sale is for less than fair market value, our Income Tax Act deems the sale amount to be FAIR MARKET VALUE. So, if you receive only $1,000 for your sales but the fair market value was $10,000, you would pay tax on the $10,000 amount. Now where will you find money to pay the tax on the additional $9,000 ($10,000-$1,000) that you didn't receive? 3. GAAR - THE STINK TEST: -------------------------- If you miraculously escape the first two problems, Revenue Canada has an additional weapon in its arsenal - GAAR the stink test. GAAR stands for the general anti-avoidance rules. Where you set up an intermediary company or a series of transactions mainly to avoid paying Canadian taxes, GAAR will set aside what you reported and tax you on what really happened. GAAR will not attack you for claiming a deduction for your RRSP contribution because the Government sanctions it. But if you sell something for little or no profit to a tax haven company that then sells it for a profit, GAAR could shift the profits back to you. 4. NON-DISCLOSURE RULES: ------------------------- Of course you may decide not to report your off-shore activities. But if you get caught, you go to JAIL. A Canadian resident is taxable on his/her world income. Usually, there are two sides to any transaction: shipping and delivery slips, bank deposits and transfers, custom clearances, etc.. If the transactions are repetitive, you inevitably will get caught. It's nice to dream about not paying taxes. But hey, our taxes are not the highest in the world. Think positive! ---- Cheers, LLOYD LINDSAY - Chartered Accountant a.k.a. iceman or labish e-mail: lloydl@the-wire.com ********************************************************* It's not what you know or who you know; it's both. Iceman has spoken. ********************************************************* From letsgo@mail.bconnex.net Sun Mar 17 13:35:41 1996 Xref: elastic can.politics:52271 ont.general:32584 soc.culture.canada:20547 tor.general:36839 Path: elastic!lethe!geac!onramp.ca!grumpy.insinc.net!news.bconnex.net!news From: letsgo@mail.bconnex.net (Linus T. Guerre) Newsgroups: can.politics,ont.general,tor.general,soc.culture.canada Subject: Re: fascist Harris Date: Sun, 17 Mar 1996 02:11:56 GMT Organization: Lets Go !!! Lines: 128 Message-ID: <4ih36l$t6v@news.bconnex.net> References: <4h5pfo$45h@spinne.web.net> <313de792.28925980@205.208.30.3> <4hv8qq$j04@ds2.acs.ucalgary.ca> <3146e741.12185968@205.208.30.3> <4iemei$679@kryten.awinc.com> NNTP-Posting-Host: auto-186-100.bconnex.net X-Newsreader: Forte Free Agent 1.0.82 Jen Thing, You seem bitter, vicious, and angry. Your hatred for all things "non-working stiff' is irrational. Calm down. Take a pill. Try and take a deep breath before responding. The world isn't that bad is it ? OK, are you ready - all calmed down... I own a business. It was incorporated 14 years ago. My observations are not theoretical but factual. They are as follows; We pay taxes - lots of them. Two years ago we lost money. That is, we spent more to operate our company than we earned by operating it. Still, we paid taxes. We paid all the usual "value added" taxes on everything we bought (which was plenty). We operate in Ontario so that meant 8% on virtually every purchase our million dollar corporation spent. We paid GST as well, but in all fairness, we get most of that credited back to us. We have to figure it all out though, which costs us money - we spend money to not have to pay tax in this example ! We have an office, and seven different locations throughout Ontario. We paid real estate taxes to each municipality for each unit we operate. We also paid a similar amount on the parking lots we share at each location. We then paid a separate business tax, again, on both each actual operation and the parking area. This all used to be at a rate of 30% of the assessed value - but as punishment for growing, this jumped to 50% when we added our sixth outlet. We also had to buy a string of permits, licences, and other municipal fees - along with enough paperwork and bureaucratic hassle to cause us to hire another office worker to keep track of it all. A new job created, fair enough, but I would rather have spent the money on a productive employee rather than one to handle the red tape. Once agin, money spent for compliance is a tax in itself. Our payroll is just under 60% of our gross income - high for our industry. For every $100.00 each employee was required to pay into the CPP, we paid a matching "tax" of $100.00. For every $100.00 of UIC, we paid a matching tax of $140.00. We also paid 100% of each persons OHIP at a rate of just under 1% of our total payroll. We have to keep track of all this - buy the software, the hardware, keep the records, employ the people to do so. A cost of doing business true enough - but another cost directly related to taxation rather than production. We have to file complicated financial statements and taxation forms every year. We can't run down to H&R Block though. We employ an accountant to the tune of thousands of dollars just to figure out that we lost money and still paid a wack of tax. It's true, Jen Thing - I paid myself too. I was also the highest paid person on the payroll - for the first time in 12 years. I use my truck for business so I claimed it as a deduction. To keep the business running I have to be available 24 hours a day, seven days a week, so I have an office in our house. I claimed that as well. Since our business is spread all over the province I travel - a lot!! When I have to be away from my family I charge the cost of the hotel against the business. I try to make the most of every trip and meet with our managers over lunch or dinner, I write off half those meals as well. Last year we were negotiating on a sizable new territory. It meant a complicated set of meetings and "shmoozing" - I wanted concessions from people who had things I needed to make the deal. It meant a great deal of travel, correspondence, and long distance telecommunications. We agreed that it would be cheaper and faster if we all met in a neutral place. There was an upcoming industry conference in New Orleans so we met there. I wrote the trip off against business income ( I had a great time and got the deal done ). Our next four stores, with all the construction, employment, and taxes are a direct result of the expense. This year we actually turned a profit, for the first time in several years. Our actual tax rate, the amount of tax we were required to pay totalled 23% of our net income. We reduced this amount by the amount of the loss from our previous year, but still, we had not made provision for that much money. We had to pay in installments, and paid penalties and interest far above private rates as a result. I have a large boat, snow mobiles, a new truck every two years, a home in the country, and all the latest gadgets. I pay taxes on all of it, as well as a personal income tax rate of just under 50%, reduced that is, by the amounts I personally spend to keep my business running as I stated in the examples above. I have RRSP's, and some savings and the equity in my possessions, but for the most part, the lions share of my personal income returns to the economy in the form of personal spending. I consume at the rate of several of our entry level employees. It all attracts tax. It all is consumption which causes employment. Our current year will be our best ever. We are making tax provisions far in excess of the 23% from last year. We are earning more, so we are paying more tax. We are earning more so we are spending more, and paying more tax. We are earning more so we are expanding faster, adding new jobs and opportunities as we go - and paying more tax. Since we are earning more, I assume I will be earning more, and spending more, and paying more tax, and creating more jobs and economic activity in my community. Dear Jenn Thing, where is the injustice in any of this? How, exactly, am I raping our country, or trampling the rights of the common man ? What advantages do I have that others do not - what opportunities, what boys club, what secret society do I benefit from at the expense of the poor, downtrodden working stiff? I alone paid more tax last year than you will in ten. I also created jobs, consumption, opportunities and economic activity. I'm happy to pay the tax if it mean's continued opportunity for me and my family and friends. The difference is - I'm not bitter. I love this country and the opportunities it has given to me. It's just that I, and others like me, seize those opportunities and try and make something of them, rather than rail furiously away at those who have what I do not. Is it still your opinion that I, and all the other business owners, entrepreneurs, corporations, and non-labourers be stripped of our possessions and given shovels and tattooed numbers on our fore arms ? Or maybe you might grudgingly admit that we all play an important role in our society, however different those roles might be. ******************************** -------------------------------- " Everybody Just Calm Down... " Linus T. Guerre Letsgo@mail.bconnex.net From elastic!lethe!geac!herboid!whome!infoshare!n2ott.istar!ott.istar!istar.net!tor.istar!east.istar!news1.istar.ca!news Thu Oct 10 20:50:01 1996 Xref: elastic can.legal:11166 can.taxes:3284 Path: elastic!lethe!geac!herboid!whome!infoshare!n2ott.istar!ott.istar!istar.net!tor.istar!east.istar!news1.istar.ca!news From: matlas@taxca.com (Michael I. Atlas) Newsgroups: can.legal,can.taxes Subject: Re: A SALESMAN Date: 7 Oct 1996 13:30:51 GMT Organization: Michael I. Atlas, Practice Retricted To Tax Lines: 122 Message-ID: <53b0mb$9kk@news.istar.ca> References: <3257DBC5.4A41@mgl.ca> <538kd5$6lp@news.istar.ca> <32588694.1524@mgl.ca> NNTP-Posting-Host: ts37-06.tor.istar.ca In article <32588694.1524@mgl.ca>, taylor@mgl.ca wrote: > Michael I. Atlas wrote: > > > > In article <3257DBC5.4A41@mgl.ca>, taylor@mgl.ca wrote: > > > > > A taxpayer , an employee, has three employers. He is a salesman on > > > salary plus commission; deductions are made at source (by the employer). > > > The taxpayer did not reveal nor did the employers ask "are you working > > > for anyone else?" > > > This "creative" entrepreneur intends to file "three" tax returns and > > > claim and deduct accordingly. Within a year his income will exceed > > > $150,000.00. No conflict in sales positions; sells three separate > > > services; neither employer knows of the other for which he is employed. > > > The salesman works 24 hours a day....win fax pro 7. > > > What are the employment problems, at law, if any? > > > What are the tax problems, at law, if any? > > > > > > Bill > > > > I cannot comment on the employment law issues. > > > > However, how can he file THREE tax returns-are you serious? Does he have > > three SIN/ Rev Can account numbers? > > Yes..By filling out three tax returns....One SIN no. ( On the other hand > maybe it's better to have 3 SIN nos?) > > > > Even if he did, certainly no one could suggest that this was legal, since > > a tax return should include ALL income, not just a part of it, and to file > > on that basis would be, in my view, a type of fraud. > > Where is the "fraud"? All income is reported and tax deducted at source. > Each employer complies, allows basic exemptions (3 times etc). You have > provided a theory only and no basis, in law, in support thereof. Where > in the Act is this exercise prohibited? If it is not prohibited it can > hardly be considered a fraud or illegal. > > > How would this be any different than any other taxpayer who has more than one source >of income (eg. investment income, capital gains, employment income) filing separate > > returns for each source in order to pay a lower rate? > > To pay a lower rate of tax is a benefit. The exercise, at this stage, is > employment income only, source deductions and that which flows from > employer obligations only. > > > > If that could work, why would we tax practioners have to worry about tax planning > > aimed at "income splitting"-a person could just do it with himself. Get real! > > "If that could work" That is the question! Very good. What is the > answer? Well, as for tax practioners, they could get some sleep and not > have to "worry"..true? > > Bill Bill- After reading your highly astute and scholarly response to my (and Hugh Neilson's) post, I have become convinced that you are absolutely correct! I apologize for any initial skepticism I may have displayed. I suppose that is something that all geniuses who come out with new and creative ideas must experience when having to explain their ideas to the dimwitted masses such as us. But now I have seen the light, and I feel truly humbled and honoured to be corresponding with a thinker of your greatness. I want to commend you for developing a revolutionary new concept in tax planning which will do away with traditional approaches to "income splitting" based tax planning. No more need to worry about attribution rules and the like-just whip that extra income onto another tax return for YOURSELF! In your honour, I am now publicly dubbing this technique "TAYLOR TAXPAYER CLONING". Perhaps being identified as the one who so dubbed it may secure for me some place in the history of the world's great ideas and inventions-a modest place compared to yours, but still a place. After having seen the light, I went out the first thing this morning to the Post Office and sent in applications for four (4) spanking new sets of Social Insurance Numbers. I would have sent in applications for more, but I did not want to be greedy, and besides, my office/residence is not big enough to house more than four additional Michael Atlases. Any more, and I would have to move out, and let them live and work here alone. My first challenge in applying your genius to my own situation was the fact that, unlike the salesman in your question with his different T4s, I only have one source of income (i.e. the income from my professional practice). Then it came to me! (perhaps some of your genius has rubbed off on me even though our contact has only been via cyberspace)-I will form a PARTNERSHIP with the other four Michael Atlases to continue to conduct my professional practice. As a matter of fact, I just finished filling out the 97(2) election a minute ago to "roll" my business into that partnership. Furthermore, since all of the other four Michael Atlases have roughly the same skills and abilities as I do, we will split the income from the partnership equally-how could Revenue Canada possibly quarrel with that? I am happy to tell you that, so far, the partnership is working out really well. Right after I finished the 97(2) election, we had our first partnership meeting, and guess what? I was elected Managing Partner! I have discussed with my partners all the benefits we are going to have, and they go far beyond anything hinted at in your post. Think of the RRSP implications! Each of us will be able to make our own contributions based upon our own contribution limits. If only I could have thought of this years earlier! (But then again, I did not even think of it now, and never would have without your tutelage). My partners and I also discussed the fact that we are going to have a fantastically secure retirement too. In addition to all of our RRSPs, we will each be able to collect some CPP, although the other four will not have full pensions because they are starting late. On top of that, none of us will ever have our Old Age Pensions "clawed back" since, even if I (oops!-I mean "we") keep working after retirement, none of us will have incomes that would be high enough to result in such bad stuff. Again, I cannot thank you enough, Bill, for what you have done for me (and my 4 partners)! -- Michael I. Atlas Practice Restricted To Tax Toronto, Ontario Voice: (416) 932-2211 Fax (416) 932-2214 E-Mail: matlas@taxca.com From elastic!lethe!gts!nypl!demon.uunet.ca!news.uunet.ca!world1.bellatlantic.net!news2.cais.net!news.cais.net!van-bc!unixg.ubc.ca!noc.van.hookup.net!news Thu Oct 10 20:51:12 1996 Xref: elastic can.legal:11217 can.taxes:3301 Path: elastic!lethe!gts!nypl!demon.uunet.ca!news.uunet.ca!world1.bellatlantic.net!news2.cais.net!news.cais.net!van-bc!unixg.ubc.ca!noc.van.hookup.net!news From: hneilson@access.awinc.com Newsgroups: can.legal,can.taxes Subject: Re: A SALESMAN Date: Tue, 08 Oct 1996 09:35:01 GMT Organization: HookUp Communication Corporation, Vancouver, BC, CANADA Lines: 71 Message-ID: <53ekv9$hp@noc.van.hookup.net> References: <3257DBC5.4A41@mgl.ca> <538kd5$6lp@news.istar.ca> <53b0mb$9kk@news.istar.ca> <1996Oct7.153104.8570@venus.gov.bc.ca> NNTP-Posting-Host: pmeb14.access.awinc.com X-Newsreader: Forte Free Agent 1.0.82 dtsai@ssbux1.env.gov.bc.ca (Dave Tsai) wrote: >Michael I. Atlas (matlas@taxca.com) wrote: >> In article <32588694.1524@mgl.ca>, taylor@mgl.ca wrote: >> > Michael I. Atlas wrote: >> > > >> > > In article <3257DBC5.4A41@mgl.ca>, taylor@mgl.ca wrote: >> > > >> > > > A taxpayer , an employee, has three employers. He is a salesman on > [snip, snip...] >> I want to commend you for developing a revolutionary new concept in tax >> planning which will do away with traditional approaches to "income >> splitting" based tax planning. No more need to worry about attribution >> rules and the like-just whip that extra income onto another tax return for >> YOURSELF! In your honour, I am now publicly dubbing this technique "TAYLOR >> TAXPAYER CLONING". Perhaps being identified as the one who so dubbed it >> may secure for me some place in the history of the world's great ideas and >> inventions-a modest place compared to yours, but still a place. >> After having seen the light, I went out the first thing this morning to >> the Post Office and sent in applications for four (4) spanking new sets of >> Social Insurance Numbers. I would have sent in applications for more, but >> I did not want to be greedy, and besides, my office/residence is not big >> enough to house more than four additional Michael Atlases. Any more, and I >> would have to move out, and let them live and work here alone. >> My first challenge in applying your genius to my own situation was the >> fact that, unlike the salesman in your question with his different T4s, I >> only have one source of income (i.e. the income from my professional >> practice). Then it came to me! (perhaps some of your genius has rubbed off >> on me even though our contact has only been via cyberspace)-I will form a >> PARTNERSHIP with the other four Michael Atlases to continue to conduct my >> professional practice. As a matter of fact, I just finished filling out >> the 97(2) election a minute ago to "roll" my business into that >> partnership. Furthermore, since all of the other four Michael Atlases have >> roughly the same skills and abilities as I do, we will split the income >> from the partnership equally-how could Revenue Canada possibly quarrel >> with that? I am happy to tell you that, so far, the partnership is working >> out really well. Right after I finished the 97(2) election, we had our >> first partnership meeting, and guess what? I was elected Managing Partner! > [more snips (to keep length down)] >Har, ha, ha, ha... >One of the best postings I have seen in a while. For sure! >David. The real beauty of Michael's plan is the ability to keep future taxes down by the admission of new partners. By sleeping in shifts, Michael's residence can surely support 10, perhaps 15, Michael Atlas's. If the partnership's income were to double, who could argue against the admission of 5 more partners to handle the increased workload? You may wish to proceed carefully - Michaels 1 through 5 will have worked hard to build the practice up, and should benefit. Perhaps you should hire Michaels 6 through 10 as employees, at least until you see how well they fit in with the organization. Hugh Neilson, CA Gardiner Karbani Audy + Partners The opinions expressed herein are those of the writer, and not necessarily those of the firm. From elastic!lethe!whome!ve3ied!loki.tor.hookup.net!news Thu Oct 10 20:53:03 1996 Xref: elastic can.legal:11222 can.taxes:3302 Path: elastic!lethe!whome!ve3ied!loki.tor.hookup.net!news From: usenet@bateman-mackay.com (Bateman MacKay Chartered Accountants) Newsgroups: can.legal,can.taxes Subject: Re: A SALESMAN Date: 9 Oct 1996 13:57:57 GMT Organization: Bateman MacKay Chartered Acccountants Lines: 53 Message-ID: <53gb15$7gn@loki.tor.hookup.net> References: <3257DBC5.4A41@mgl.ca> <538kd5$6lp@news.istar.ca> <32588694.1524@mgl.ca> <53b0mb$9kk@news.istar.ca> Reply-To: doerbecker@bateman-mackay.com NNTP-Posting-Host: bateman.tor.hookup.net X-Newsreader: WinVN 0.93.11a First off, Michael: I enjoyed your idea of multiple Michael Atlas'. This was the best planning idea ever. Sure overshadowed the entire Ontario Tax Conference (held by the Canadian Tax Foundation on Oct 7 & 8) and most of the discussions we had on Income Splitting. However, Bill asked for the basis in law that prohibited a person from filing 3 tax returns. My initial reaction is in combination of Section 2 and 3 of the Income Tax Act (RSC 1985 c 1 (5th Supplement)...) Subsection 2(1) reads as follows: "An income tax shall be paid, as required by this Act, on the taxable income for each taxation year of every person resident in Canada at any time in the year." This subsection on the surface does not prohibit the 3 return approach. Subsection 2(2) defines Taxable Income as "... the taxpayer's income for the year plus ... and minus ... Division C" Section 3 further defines the income of a taxpayer as follows: "The income of a taxpayer for a taxation year for the purposes of this part [I] is the taxpayer's income for the year determined by the following rules: (a) determine the TOTAL OF ALL AMOUNTS each of which is the taxpayer's income for the the year (other than a taxable capital gain from the disposition of a property) from a source inside or outside Canada, including, without restricting the generality of the foregoing, the taxpayer's income for the year FROM EACH OFFICE, EMPLOYMENT, BUSINESS and property, (b) ...[capital gains in excess of capital losses]" [emphasis added] Therefore, these sections state that each taxpayer will include all income from all sources in one calculation of taxable income, resulting in only 1 tax return. Bill: I trust this is the basis in law you were looking for, that Mr. Atlas and Mr. Neilson knew intuitively. Barry Doebecker doerbecker@bateman-mackay.com Staff Accountant ________________________________________________ Bateman MacKay Chartered Accountants Burlington, Ontario, Canada Focused on Research & Development Tax Credits http://www.bateman-mackay.com Disclaimer: The views expressed here are those of the author and may not reflect those of Firm. From elastic!lethe!gts!torfree!news1.io.org!newsfeed.direct.ca!van.istar!west.istar!ott.istar!istar.net!tor.istar!east.istar!news1.istar.ca!news Thu Oct 10 20:54:22 1996 Xref: elastic can.legal:11194 can.taxes:3295 Path: elastic!lethe!gts!torfree!news1.io.org!newsfeed.direct.ca!van.istar!west.istar!ott.istar!istar.net!tor.istar!east.istar!news1.istar.ca!news From: matlas@taxca.com (Michael I. Atlas) Newsgroups: can.legal,can.taxes Subject: Re: A SALESMAN Date: 9 Oct 1996 14:34:03 GMT Organization: Michael I. Atlas, Practice Retricted To Tax Lines: 37 Message-ID: <53gd4r$q2e@news.istar.ca> References: <3257DBC5.4A41@mgl.ca> <538kd5$6lp@news.istar.ca> <32588694.1524@mgl.ca> <53b0mb$9kk@news.istar.ca> <53gb15$7gn@loki.tor.hookup.net> NNTP-Posting-Host: ts63-04.tor.istar.ca In article <53gb15$7gn@loki.tor.hookup.net>, doerbecker@bateman-mackay.com wrote: > First off, Michael: I enjoyed your idea of multiple Michael Atlas'. This > was the best planning idea ever. Sure overshadowed the entire Ontario Tax > Conference (held by the Canadian Tax Foundation on Oct 7 & 8) and most of > the discussions we had on Income Splitting. > > However, Bill asked for the basis in law that prohibited a person from > filing 3 tax returns. > > > Bill: I trust this is the basis in law you were looking for, that Mr. > Atlas and Mr. Neilson knew intuitively. > Barry- Thanks for your post. Obviously, what you are saying is correct, but I believe that we are all wasting our time in trying to deal with Bill as a rational human being. The basis you gave is quite similar, in many respects, to the one that Hugh Neilson gave in his detailed post of October 7, 1996. But in Bill's reply on that same date he stated "I must complement you on your efforts; however, I found nothing of substance to suggest the exercise may not be successful". Do you want to guess what Bill will say in response to your post? -- Michael I. Atlas Practice Restricted To Tax Toronto, Ontario Voice: (416) 932-2211 Fax (416) 932-2214 E-Mail: matlas@taxca.com From elastic!lethe!gts!whome!telly!problem!ve3tsx!news.interlog.com!news Thu Oct 10 20:55:37 1996 Xref: elastic can.legal:11192 can.taxes:3294 Path: elastic!lethe!gts!whome!telly!problem!ve3tsx!news.interlog.com!news From: alchemy@interlog.com (Morton M. Goldmacher) Newsgroups: can.legal,can.taxes Subject: Re: A SALESMAN Date: Wed, 09 Oct 1996 18:39:15 GMT Organization: Barrister and Solicitor Lines: 25 Message-ID: <53gkuh$jq8@news.interlog.com> References: <3257DBC5.4A41@mgl.ca> <538kd5$6lp@news.istar.ca> <32588694.1524@mgl.ca> <53b0mb$9kk@news.istar.ca> <53gb15$7gn@loki.tor.hookup.net> <53gd4r$q2e@news.istar.ca> Reply-To: alchemy@interlog.com NNTP-Posting-Host: ip93-209.tor.interlog.com X-Newsreader: Forte Free Agent 1.0.82 matlas@taxca.com (Michael I. Atlas) wrote: >Do you want to guess what Bill will say in response to your post? I'll take that one on. Bill has a few stock replies to solid statements that rent his nonsense. Chose from these: (a) Nice try, think again. (b) That is theory, any proof? (c) That is nowhere in law... (d) an opinion only. Can you prove? Among his favorite non-replies is to characterize a cogent and explicit legal fact as a mere opinion or a theory and then demand some sort of further authority or validation. Rather than waste my time in discussions with Mr. Taylor, I've taken up the task of teaching my goldfish to play the piano. Its more gratifying, less demanding, an on the whole a lot more rational. Morton M. Goldmacher Barrister and Solicitor Piscetarian Tutor