Canadian estate and tax advisors may want to consider the case Connelly v. Internal Revenue Service, No. 23-146[1] (U.S. 3/27/24). The U.S. Supreme Court (“SCOTUS“) issued its decision on June 6th and it serves as a good reminder of the implications of corporately-owned life insurance in the context of cross-border…
Gwenyth Stadig, Associate and Upama Poudyal, Articling Student – Gowling WLG (Canada) LLP An increasing number of Canadian taxpayers are interested in giving pieces of art to charities or other qualified donees as part of their estate plans. Some of these Canadian taxpayers are choosing to make decisions to give…
For my last blog post, I discussed the potential financial value of an individual’s “personalty” and clauses in wills governing such personalty. While an individual’s more traditional assets may include bank accounts, real estate or vehicles, there may also be some other personal items (e.g. collections) that may have significant…
These days, it is quite common to find intergenerational wealth transfer to consist of property held in a discretionary family trust whose beneficiaries may or may not have been in marital relationships at the time of the time the trusts were created. A siginifcant number of legal and financials issues…
Canadian Tire “money” has been distributed by Canadian Tire stores for almost 65 years. While CT Money is often dismissed, it may be a mistake to ignore the bills as a potential asset of the estate.
In a recent case in Tax Court, Lauria v HMQ 2021 TCC 66, the taxpayers, both officers and directors of a company held shares in the company as a result of employee share option agreements granted to them. In early 2006, the company founders decided to pursue an initial public…
