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S.85 Tax Exempt Transfer to a Corp.

Section 85 of the Income Tax Act is a commonly used provision that permits the tax exempt transfer of property to a corporation. This paper provides an overview of the application of the section covering key topics including the general rules of section 85, eligible property, consideration or “boot,” anti-abuse rules, requisite filings and other related provisions of the Act.

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NAFTA Domestic Tax as Trade Subsidy

This paper argues that North American Free Trade Agreement (NAFTA) renegotiation and amendment should be used to define and restrict domestic tax provisions improperly used as indirect trade subsidies or tariffs. In doing so the Canadian foreign affiliate rules and the proposed US border adjustment tax are examined.

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US Real Estate Tax Issues

US Tax Issues for Canadians

This paper provides an overview of relevant tax considerations when a Canadian resident is purchasing US real estate and discusses different ways to structure a purchase to minimize tax exposure.

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Using a Family Trust in Business

Family Trusts for Business

The discretionary family trust is a tool used by some business owners to reduce tax liability and increase flexibility in the family economic unit by facilitating tax-favourable distribution of funds, business succession and estate planning. Using a discretionary family trust to hold shares in a private company can have significant tax and planning benefits. This paper seeks to provide an overview of the beneficial uses of a trust by the owner of a privately held corporation in Canada.

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