Florence Marino

All Articles Capital Dividend Account Capital Gains Capital Loss Carry Back Planning Charitable Gifts Pipeline Post-Mortem Planning

January 8, 2025

Capital gains inclusion rate change – To be or not to be?

Here is our take on the recent political and administrative events that have unfolded to start 2025 focusing on the capital gains inclusion rate change that is not yet law.

Florence Marino

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All Articles Capital Gains Corporate Ownership Life Insurance Tax Non-Tax & Practical Issues Personal Ownership Post-Mortem Planning

December 11, 2024

Joint last-to-die life insurance – Food for thought

When is joint last-to-die life insurance the right fit? And when is it not? Here are some considerations.

Florence Marino

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November 27, 2024

The nuts and bolts of interest deductibility and leveraged life insurance – A primer

For a review of interest deductibility in the context of leveraged life insurance.

Florence Marino

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November 13, 2024

Trust rollout of life insurance – Confirmed in writing

The CRA’s long-standing position allowing a rollout of a life insurance policy from a trust has been confirmed in writing at the recent APFF Conference.

Florence Marino

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All Articles Non-Tax & Practical Issues

October 30, 2024

The quest for corporate beneficial ownership information – Where it’s at and where it’s going

Transparency of corporate beneficial ownership information is required to be publicly available for companies incorporated under the Canada Business Corporations Act. For an update on corporate beneficial ownership in Canada.

Florence Marino

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All Articles Business Succession

October 16, 2024

A business succession story – As told by the Tax Court

A tax case chronicles the story of a family business succession with a happy ending.

Florence Marino

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All Articles Anti-Avoidance Estate Freezes

October 2, 2024

CRA Guidance on Mandatory Disclosure – Contingent fees

CRA guidance on mandatory reporting says referral fees in respect of estate freeze transactions and the acquisition of life insurance do not require mandatory reporting. Positive for mainstream non-aggressive tax planning connected to life insurance…

Florence Marino

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All Articles Charitable Gifts Corporate Ownership Personal Ownership

September 11, 2024

The rundown on in-kind charitable gifts of life insurance and some recent clarifications

For considerations and rules relating to in-kind gifts of life insurance and an update on recent, specialized clarifications from the 2024 CALU CRA Roundtable and the August 12, 2024 draft legislation concerning life insurance gifts.

Florence Marino

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All Articles Capital Loss Carry Back Planning Post-Mortem Planning

August 28, 2024

Technical amendment expands the time frame for post-mortem capital loss carry-back planning

We welcome the August 12, 2024 technical amendment to subsection 164(6) which extends the time frame for post-mortem capital-loss carry back planning.

Florence Marino

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All Articles Business Succession EOTs Life Insurance Tax Trusts

July 31, 2024

Legislative loose ends

For an update on enacted tax legislation and some of the loose ends we’ve been following.

Florence Marino

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Capital gains inclusion rate change – To be or not to be?

Joint last-to-die life insurance – Food for thought

The nuts and bolts of interest deductibility and leveraged life insurance – A primer

Trust rollout of life insurance – Confirmed in writing

The quest for corporate beneficial ownership information – Where it’s at and where it’s going

A business succession story – As told by the Tax Court

CRA Guidance on Mandatory Disclosure – Contingent fees

The rundown on in-kind charitable gifts of life insurance and some recent clarifications

Legislative loose ends

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