Articles

Estate Freezes

Sep 4, 2017
Deer

Estate freezes are used by family business owners to facilitate the transfer of a business from one generation to the next while taking advantage of available tax deductions and incentives. They are generally structured to minimize capital gains tax and probate fees and to take advantage of dividend sprinkling to income split among family members,…

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S.85 Tax Exempt Transfer to a Corp

Jul 27, 2017
Cherry blossoms

Section 85 of the Income Tax Act is a commonly used provision that permits the tax exempt transfer of property to a corporation. This paper provides an overview of the application of the section covering key topics including the general rules of section 85, eligible property, consideration or “boot,” anti-abuse rules, requisite filings and other…

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NAFTA Domestic Tax as Trade Subsidy

Apr 30, 2017
Mexican Farmer

This paper argues that North American Free Trade Agreement (NAFTA) renegotiation and amendment should be used to define and restrict domestic tax provisions improperly used as indirect trade subsidies or tariffs. In doing so the Canadian foreign affiliate rules and the proposed US border adjustment tax are examined. Download the full paper here: Nick Wright…

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Canada-Barbados Tax Treaty

Dec 28, 2016
Barbados Beach

This paper explains how to use the Canada-Barbados Tax Treaty to avoid Canadian tax on international business income. Download the full paper here: Nick Wright Canada Barbados Tax Treaty Controversy & Reform 161228 This article and the contents herein are for informational purposes only and do not constitute legal advice. Readers are advised to seek…

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