Steven Frye

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Baker Tilly WM LLP is a leading, independent audit, tax, and business advisory firm based in Vancouver and Toronto, serving clients across Canada. Drawing on well-trained teams across a variety of disciplines, we ensure the alignment of our professional’s skills and experience with client requirements, resulting in exceptional service and business outcomes.

Another Resolution for the New Year – Take Advantage of the Low Prescribed Rate

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We have talked about income splitting arrangements available to individuals who wish to loan funds to his/her lower income spouse or adult child, or in the case of minor children, a discretionary family trust. Such loans would be used to invest in income producing properties such marketable securities, mutual funds, real estate income trusts (to name a few). The income from these properties less the interest paid on the loans….

Another Resolution for the New Year – Take Advantage of the Low Prescribed Rate Continue Reading »

Canada Revenue Agency, Estate Planning, Interest, Loans, Property, Real Estate, Tax Issues, Trusts

Capital Gains Exemption Purification before a Share Sale: Be Careful about Timing

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Assume a family trust (“Trust”) which has a December year end owns 100% of an operating company (“opco”). A separate corporation (“holdco”), owned by the founders of opco, is a corporate beneficiary of the Trust. Opco is up for sale. Opco has excess funds which may affect the Trust’s and its beneficiaries’ ability to claim the capital gains exemption. A common technique to purify opco for capital gains exemption purposes….

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Canada Revenue Agency, Estate Planning, Investments, Property, Small Business, Succession Planning, Tax Issues, Trusts

Requirement to File a Tax Return Expanded

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As written previously, the requirement to file a tax return for trusts has been expanded. Thanks to new legislation, there are now exceptions to the exception to file. Generally speaking, a trust (other than a trust established by law or judgment) that is resident in Canada must file a tax return, unless the trust had been in existence for less than three months at the end of the year or….

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Canada Revenue Agency, Estate Administration, In the News, Investments, Tax Issues, Trusts

Source of Income and the TOSI Rules: Clarification?

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Since the Tax on Split Income (“TOSI”) legislation was released, there has been considerable consternation amongst professionals as to how the rules apply. Even the most sophisticated readers of the legislation agree that it contains provisions that are both ambiguous and somewhat complicated. Somewhat out of exasperation, many deal with the TOSI rules on the assumption that all income amounts received by shareholders, beneficiaries, and partners are subject to TOSI,….

Source of Income and the TOSI Rules: Clarification? Continue Reading »

Canada Revenue Agency, Estate Planning, In the News, Investments, Property, Real Estate, Small Business, Tax Issues, Trusts

Fair Market Value Used to Test the Meaning of All or Substantially All of the Assets Used in an Active Business

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Under The Income Tax Act (“ITA”), if a taxpayer disposes of property that is all or substantially all of the assets used in an active business for consideration that includes shares of a corporation, the shares are deemed to be capital property. The disposal is considered to be a capital gain and may be eligible for the lifetime capital gains exemption for qualifying companies. This is a very important piece….

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Business Succession Planning, Canada Revenue Agency, Estate Planning, In the News, Investments, Property, Small Business, Tax Issues, Uncategorized

Tax Appeals in Estates and Legal Standing

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In the land of income taxes and income tax law, it is generally understood that a taxpayer cannot appeal another taxpayer’s assessment without legal standing to do so. This is particularly relevant when the taxpayer being assessed or re-assessed is deceased. In the Estate of Straessle v. the Queen 2018 DTC 1106, the issue of legal standing was put to the test with interesting results. Sometime ago, The Canada Revenue….

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Canada Revenue Agency, Estate Administration, Executors, Tax Issues, Trusts, Uncategorized
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