Articles

We live in a world of rootless capital, where finance flows readily across borders. Many businesses operate internationally with resulting assets held in multiple jurisdictions. These intricate, globe-straddling financial portfolios have been the bane of tax authorities, tasked with monitoring and enforcing tax liabilities on assets held abroad. Blind spots – jurisdictions that the authorities…

Canadian Charities take note: a fundamental shift has occurred in how the Canada Revenue Agency regulates political activities, one that may significantly change the way that charities engaged in non-partisan political activities structure themselves and operate. Though punctuated by the Trudeau government’s recent decision to drop its appeal against a 2018 court ruling that struck…

One of the most significant regulatory developments of the past few years regards changes to offering memorandum exceptions, and every Canadian business owner and investor should be aware of how these new rules work.   In 2016, a set of new amendments from provincial securities regulators came into force. They introduced an offering memorandum prospectus…

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,…