Corporate Ownership – Page 2 – Tompkins Insurance

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

July 3, 2024

Post-mortem planning – Some updates

For an update on recent post-mortem planning items and a reminder that life insurance can fund tax liabilities arising in respect of owning private company shares on death.

Florence Marino

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

June 25, 2024

Capital gains inclusion rate details – Thinking about the long term

The details of the capital gains inclusion rate increase are out. No big surprises. Think beyond June 25 and asses the long term impacts. Your clients might need more insurance.

Florence Marino

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All Articles Capital Dividend Account Capital Gains Corporate Ownership

May 17, 2024

The increased capital gains inclusion rate – Quantifying the hit

The proposed new capital gains inclusion rate will result in a difference of 8.56 percentage points. Is the actual impact 8.56% or is it 32%?

Paul Tompkins

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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 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…

Florence Marino

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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…

Florence Marino

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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.

Florence Marino

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Corporate Ownership21

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

Post-mortem planning – Some updates

Capital gains inclusion rate details – Thinking about the long term

The increased capital gains inclusion rate – Quantifying the hit

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

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Waterloo Region

Corporate Ownership21

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Toronto

Waterloo Region