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…
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.
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…
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.
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.
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…
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…
