All Articles – Page 6 – Tompkins Insurance

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 Articles Corporate Ownership Trusts

November 30, 2023

Absurdly problematic – Life interest trusts and corporate-owned life insurance

The CRA has confirmed its prior comments that corporate-owned life insurance could taint a spousal trust and impact a rollover of capital property to the trust. Problematic? Yes. Absurd? Yes.

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All Articles Business Succession Capital Gains Intergenerational Business Transfers

November 15, 2023

What does life insurance have to do with proposed intergenerational business transfers? – Lots

The business succession tsunami (See: Succession Tsunami: Preparing for a decade of small business transitions in Canada (cfib-fcei.ca) expected in the next decade in Canada should not come as a surprise. Demographic factors, growth in…

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All Articles Anti-Avoidance

November 2, 2023

A new GAAR – Pretty chilly right now

On August 4, 2023, the Department of Finance released revised draft legislation (“the proposals”) that would amend the general anti-avoidance rule (GAAR) in the Income Tax Act (the Act). Given the very short comment period…

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

October 26, 2023

Looking back and looking forward

Over the past 30 years the acceptance and deployment of life insurance within estate and business succession planning has blossomed. In large part, we attribute this increased utilization to a greater understanding of the unique…

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