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.

Infant Beneficiary of a Family Trust and the Capital Gains Exemption

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Pursuant to the Income Tax Act, to be eligible for the capital gains exemption, the qualified small business corporation share definition includes a requirement that it be held by the taxpayer, or a party related to the taxpayer “throughout the 24 months” preceding sale. Under the circumstances, can an 18th month old beneficiary of a family trust receive a distribution of otherwise qualifying small business corporation shares, sell them the….

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Canada Revenue Agency, Estate Planning, Investments, Succession Planning, Tax Issues, Trusts, Wills

CRA Collections: Dealing With Some of the Myths

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As a trustee or executor of an estate, you may find yourself managing existing or future tax disputes with the Canada Revenue Agency (“CRA”) and the collections department of the CRA at the same time. In a blog written by Peter Aprile of Countertax Lawyers entitled the Canada Revenue Agency Collection Department & Paying Tax Debts in dispute, some issues and related myths were addressed which you may find useful….

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Canada Revenue Agency, Estate Administration, Estate Administration and Probate Applications, Estate Litigation, Estate Planning, Executors, Passing Of Trustees’ and Executors’ Accounts, Tax Issues, Trustee, Trustee Disputes, Trusts, Wills

RESIDENCY OF A TRUST – A QUESTION OF MANAGEMENT AND CONTROL

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As my fellow bloggers have explained in some detail, there are various tenets governing trusts having legal and tax implications depending on the circumstances. One of these is the location of “central management and control” which the Courts have previously ruled as being the basis for determining residency. Recently, the Supreme Court of Newfoundland and Labrador was asked to rule on the specific issue of residency which would have significant….

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Canada Revenue Agency, Estate Administration, Estate Litigation, Estate Planning, Investments, Property, Trustee, Trusts

Valuations for estate planning arrangements and tax disputes.

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I was at a conference for professional valuators and appraisers from around North America. There was a session devoted to the do’s and don’ts when dealing with the tax authorities on disputes with valuations, presented by two gentlemen with considerable experience with tax disputes on both sides of the border. I was interested in hearing that while estate and gift tax returns have a high audit focus in the USA….

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Estate Planning

Valuations for estate planning arrangements: Some Tips and Traps Redux

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Recently I wrote about price adjustment clauses (PACs) in estate plan agreements. In the blog, I noted the fair market value for the purposes of PACs should be based on fair and reasonable methods. In a recent Canadian Tax Foundation bulletin, Richard Wise provided some additional observations on valuations which I think apply to not only to valuations for PACs but for estate planning arrangements in general and confirm some….

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Estate Planning

POWERS OF ATTORNEY AND ALTER EGO TRUSTS

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My fellow bloggers and I have written in the past about the ins and outs of legitimate probate fee avoidance arrangements available to a testator. These arrangements include an intervivos transfer of assets such as alter-ego trusts. Care and advice must be taken to ensure that the transfer of assets qualify for tax deferral under the Income Tax Act (“ITA”) to avoid the triggering of income taxes. Recently the Canada….

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Estate Planning
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