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Estate Freezes

Estate freezes are used by family business owners to facilitate the transfer of a business from one generation to the next while taking advantage of available tax deductions and incentives. They are generally structured to minimize capital gains tax and probate fees and to take advantage of dividend sprinkling...

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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,”...

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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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