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All Articles Capital Dividend Account Life Insurance Tax

May 1, 2024

Alternative minimum tax – Where are we now?

Life insurance is a unique asset that has many favourable tax characteristics. In general, these characteristics are not in and of themselves a problem for AMT.

Florence Marino

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All Articles Capital Dividend Account Capital Gains Capital Loss Carry Back Planning Corporate Ownership Pipeline Post-Mortem Planning

April 18, 2024

2024 Federal budget – Reflections on the increase to the capital gains inclusion rate through an insurance lens

By now you’ve read the 2024 Federal Budget summaries and digested some of the impacts. Here is what we think about the capital gains inclusion rate changes, looking through a distinctly insurance-focused lens.

Florence Marino

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All Articles Life Insurance Tax Trusts

April 10, 2024

Roll-out of life insurance policy from a trust – Undisturbed

Prior CRA commentary regarding the roll out to a capital beneficiary of life insurance at cost is undisturbed by recent commentary relating to the transfer of a life insurance policy as a dividend in-kind via…

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All Articles Anti-Avoidance Business Succession Estate Freezes

March 27, 2024

The new GAAR is already getting warmer

More good news from the CRA on the new GAAR. Common tax and estate planning transactions that were not GAAR-able before are not going to be GAAR-able now.

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All Articles Anti-Avoidance Capital Dividend Account Corporate Ownership Life Insurance Tax Pipeline

March 13, 2024

Post-mortem pipelines under the new GAAR are OK

The CRA has confirmed that it does not see post-mortem pipeline planning as a misuse or abuse under the new GAAR and will continue to issue favourable rulings. Life insurance in conjunction with post-mortem pipeline…

Florence Marino

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All Articles Anti-Avoidance Corporate Ownership Trusts

February 28, 2024

Avoiding the 21-year rule? – Be notified

Certain tax planning to avoid the 21-year rule must be reported to the CRA and in their view, subject to GAAR. Consider using life insurance to solve for problems this planning is meant to address.

Florence Marino

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All Articles Business Succession EOTs Trusts

February 14, 2024

Employee Ownership Trusts – An unchartered option for sale of business in Canada

Proposed tax measures provide a framework for a new business succession planning option. Will Employee Ownership Trusts take hold in Canada as a viable sale of business option?

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All Articles Corporate Ownership

January 31, 2024

Holdco and Sisterco owners of life insurance with Opco as beneficiary results in shareholder and indirect benefits

In the case of Gestion M.-A. Roy Inc. et al, the Federal Court of Appeal affirmed the reasoning of the Tax Court to include the amount of premiums paid by Opco in respect of policies…

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All Articles Corporate Ownership Trusts

January 17, 2024

Imperfect conduit – Transfer of a life insurance policy as a dividend-in-kind via a trust

Trusts are not perfect conduits. Dividends received in-kind by a connected corporation that is a beneficiary of a trust maintain their character as inter-corporate dividends but on the disposition of the property itself, differences in…

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All Articles Anti-Avoidance Business Succession Intergenerational Business Transfers Life Insurance Tax

December 14, 2023

Tax Legislation tabled – Some highlights

Bill C-59 implementing many measures from the 2023 Federal Budget is in progress. Here are our comments on some of the highlights.

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All Articles54

Alternative minimum tax – Where are we now?

2024 Federal budget – Reflections on the increase to the capital gains inclusion rate through an insurance lens

Roll-out of life insurance policy from a trust – Undisturbed

The new GAAR is already getting warmer

Post-mortem pipelines under the new GAAR are OK

Avoiding the 21-year rule? – Be notified

Employee Ownership Trusts – An unchartered option for sale of business in Canada

Holdco and Sisterco owners of life insurance with Opco as beneficiary results in shareholder and indirect benefits

Imperfect conduit – Transfer of a life insurance policy as a dividend-in-kind via a trust

Tax Legislation tabled – Some highlights

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