Bill C-208

Genuine intergenerational transfers

For many years, non-arm’s length intergenerational transfers of corporate businesses were treated inequitably under the Income Tax Act (ITA).  A transfer of a corporate business between non-arm’s length parties[1] resulted in dividend treatment to the vendor instead of capital gains treatment, precluding the ability to claim the capital gains deduction.  With the inability to claim the capital gains deduction and the loss of the preferential tax treatment for capital gains,….

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Succession Planning

The Finance Strikes Back

As the story of Bill C-208 (intergenerational transfers) continues to evolve, I can’t help but make analogies to my favorite childhood trilogy.  The Star Wars trilogy was a dominating force in my childhood.  I lived and breathed the interesting stories produced by this vast universe created by George Lucas. In comparison to Star Wars, our vast tax universe also produces interesting stories. The latest story involves the private member’s bill,….

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Business Succession Planning, Tax Issues
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