Income Tax Act

• VANCOUVER, British Columbia, Feb. 13, 2024 (GLOBE NEWSWIRE) -- Foremost Lithium Resource & Technology Ltd. (NASDAQ: FMST) (CSE: FAT) (“Foremost Lithium”, “Foremost” or the “Company”), a North American hard-rock lithium exploration company, is pleased to announce each of a proposed and “best efforts” non-brokered private placement to raise gross proceeds of up to $3,750,000 on a flow-through basis (the “Flow-Through Private Placement”) together with up to $1,500,000 on a non-flow-through basis (the “Private Placement”; and, collectively, with the Flow-Through Private Placement, the “Private Placements”).
• The Private Placement will be comprised of units (each, a “PP Unit”) of the Company, at a proposed subscription price of $3.40 per PP Unit.
• The proceeds from the pending Private Placement are expected to be utilized for general corporate and working capital purposes for the Company during the next 12 months.
• The proceeds from the Private Placement will be used for working capital and general corporate purposes.

• Each Warrant will entitle the holder thereof to purchase one Share (a “Warrant Share”) at an exercise price of C$0.67 for 24 months following the completion of the Offering.
• All Qualifying Expenditures will be renounced in favour of the subscribers of the Charity FT Units effective December 31, 2024.
• The net proceeds from the sale of Hard Dollar Units will be used to fund exploration and for additional working capital purposes.
• Persons unless registered under the U.S. Securities Act and applicable state securities laws or an exemption from such registration is available.

• While Labor resists calls to change Australia’s system of negative gearing and the Greens push for changes, there’s a chance change could come from somewhere else altogether – Australia’s legal system.
• As surprising as it might seem, the legal precedent that allows one million Australians to negatively gear investment properties can be challenged.

The problematic precedent

• The general deduction section allows taxpayers to deduct from assessable income any loss or outgoing to the extent that “it is incurred in gaining or producing your assessable income”.
• Where such expenses are only partly related to gaining income, the section allows that part of them be deducted, with the rest not.

How Janmor Nominees played out

• In court, the Tax Office argued that the loss shouldn’t be allowed as a deduction because the property wasn’t really rented out.
• This meant it didn’t deal with the more important question of whether negative gearing losses were incurred in gaining or producing assessable income.

Losses need to be in pursuit of income

My respectful opinion is that the judgment can’t govern negative gearing as it is usually practiced today, and for that matter, could not have governed it as it was usually practiced back in 1987. In the standard negative gearing situation, the taxpayer who incurs a rental loss after deducting rental expenses is seeking three things:
rent
capital growth for the purpose of making a profit
use of the loss to reduce other taxable income to reduce tax owed.

• The first of the three advantages (to obtain rent) satisfies the deduction test – it is connected to the pursuit of an income.
• Regardless of purpose, the courts have held that, to be deductible, expenses need to be objectively “incidental and relevant” to earning income.
• Again – objectively – interest expenses are only partly directed at obtaining rent; they are also directed at obtaining tax deductions and capital growth.

The Tax Office ought to seek a ruling

• The Tax Office would get complaints.
• The Tax Office regularly tests the boundaries of deduction provisions by bringing cases to the courts, even where political sensitivities are involved.
• It is a criticism to which the Tax Office might not have a ready answer.

Dale Boccabella does not work for, consult, own shares in or receive funding from any company or organisation that would benefit from this article, and has disclosed no relevant affiliations beyond their academic appointment.

• GRIMSBY, Ontario, Feb. 12, 2024 (GLOBE NEWSWIRE) -- The Board of Directors of Andrew Peller Limited (ADW.A / ADW.B) (the “Company”) announced today that it has approved a quarterly common share dividend of $0.0615 per Class A Share and $0.0535 per Class B Share to be paid on April 12, 2024 to shareholders of record on March 29, 2024.
• The Company has consistently paid common share dividends since 1979 and has increased dividends eight times over the last ten years, most recently in fiscal 2022.
• The Company currently designates all dividends paid as “eligible dividends” for purposes of the Income Tax Act (Canada) unless indicated otherwise.