Corporate Ownership – Page 2 – Tompkins Insurance

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 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 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 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 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…

Florence Marino

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Corporate Ownership17

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

Post-mortem pipelines under the new GAAR are OK

Avoiding the 21-year rule? – Be notified

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

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

Looking back and looking forward

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Corporate Ownership17

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

Post-mortem pipelines under the new GAAR are OK

Avoiding the 21-year rule? – Be notified

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

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

Looking back and looking forward

CATEGORIES

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Contact Us

Location