Tax Issues

Total 358 Posts

Embryo Freezing Costs: Medical Expense Tax Credit Extended to Same Sex Couples.

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The Income Tax Act (“ITA”) generally permits as an eligible medical expense of an individual, an amount paid to a medical practitioner, dentist, or nurse or a public or licensed private hospital for medical or dental services provided to a patient. Medical services are diagnostic, therapeutic or rehabilitative services that are performed by a medical practitioner acting within the scope of his or her professional training. Generally, a payment to….

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Canada Revenue Agency, Estate Planning, Healthcare, In the News, Spouse, Tax Issues, Uncategorized

Inherited assets and TOSI

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While it has been over 18 months since its implementation, we are still learning more about the application of the tax on split income (TOSI) rules.  The Canada Revenue Agency (CRA) provided guidance where shares of a private company are passed on to the children of the deceased. The CRA was asked to comment on how the TOSI rules would apply when the deceased, Mrs. A, the co-owner of a….

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Canada Revenue Agency, Estate Planning, Tax Issues

SHAREHOLDERS AGREEMENTS, EXIT PROVISIONS AND THE IMPACT OF CONTROL

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Control is an important concept for applying certain income tax rules and valuation issues (amongst others) when dealing with corporations, with serious implications to current and future (and estate) planning scenarios. De jure control refers to legal control of a corporation, which requires a look at shareholdings. Control in fact, or “de facto control”, (“DFC”) is a broader concept that focuses on influence rather than legal control. As a result,….

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

The Life of Pipeline Transactions: The Beat Goes On

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In the past few years, many associated with this blog have written about the benefit of post-mortem pipeline transactions to avoid double tax on disposition of certain assets. Again, and briefly, a pipeline transaction is a form of transaction whereby the assets of a corporation are distributed to shareholders utilizing the high adjusted cost base resulting from the capital gains realized on death, rather than as a distribution in the….

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

INCOME RECEIVED AFTER DEATH

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Recently, the Canada Revenue Agency released a technical interpretation to clarify the commentary in the T4001 Employer’s Guide – Payroll deductions and Remittances, and the T4011 guide, Preparing Returns for Deceased Persons, in respect of income payable at death but not actually paid until the subsequent year. The CRA confirmed that income payable should only be included in the T4 for the year in which it was actually paid, which….

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Canada Revenue Agency, Estate Administration, Estate Planning, Tax Issues, Uncategorized

FAMILY TRUSTS AND ALLOCATIONS OF PROCEEDS FROM SALE

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Recently, I encountered a scenario where the trustees of a family trust were planning an allocation of proceeds from a share sale transaction to the beneficiaries of trust using the lifetime capital gains exemption but it appeared that the allocated amounts would physically end up in the hands of other individuals including the trustees of the trust. It appeared in fact that certain beneficiaries would only see their allocation on….

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Canada Revenue Agency, Investments, Tax Issues, Trustee, Trusts, Uncategorized
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