ESTATE FREEZES AND CORPORATE ATTRIBUTION RULES: A QUICK REFRESHER

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When an individual taxpayer transfers or loans directly or indirectly property to a corporation, certain provisions of the Income tax Act (“the Act’) may deem the transferor to have received annual interest income on the property at the prescribed rate as set out in the Regulations of the Act. The deemed income will fluctuate with the prescribed rate and the rate is not locked in at the time of transfer…..

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Business Succession Planning, Canada Revenue Agency, Estate Administration, Estate Planning, Interest, Investments, Loans, Property, Real Estate, Small Business, Succession Planning, Tax Issues, Trustee

Rethinking Testamentary Charitable Remainder Trusts

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The tax treatment in Canada of testamentary charitable remainder trusts (CRT) has long been an exercise of metaphysical complexity. Although a charity may receive property from a trust established by will, tax receipts are rare. What looks like a gift isn’t for tax purposes. The new “estate donation” rules in sub-section 118.1(5) that became effective in 2016 have quietly changed this reality, but it may take a while for CRA….

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Estate Planning, Philanthropy/Charitable Giving

UNCLE SAM’S REACH CONTINUES – THIS TIME POTENTIALLY TO YOUR ABILITY TO TRAVEL

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Like many countries rules for being a citizen, an individual is a US citizen either because they were born in the United States or because they have become a citizen through the process of naturalization. Either way, once a US citizen you are entitled to the rights, privileges and benefits of being a US citizen. One of those privileges is the right to acquire a US passport. ….

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U.S. Citizen, United States

The Clock Ran Out On This Will Challenge

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Limitations statutes can be unforgiving. One dairy farmer learned this lesson in Reid et al. v Reid; Reid v Reid et al., 2016 ONSC 2098, when his will challenge was dismissed for being commenced out of time. Barry and Robert are brothers. Their parents, Walter and Mary, operated a dairy farm which was held by a family corporation (the parents each held 46.5% of the shares; the children each held….

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Contested wills, Estate Litigation, Executors, Family Conflict, Trustee, Wills
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