Articles

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,…

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…