Archive for the ‘Estate Planning’ Category

CRA Commentary on 74.4(2) Planning and Dividend Payments

Friday, February 5th, 2016

The CRA recently published a severed letter in which it considered the applicability of subsection 74.4(2) to two scenarios involving the payment of dividends from a small business corporation to a holding company, for the benefit of “designated persons”. Generally, subsection 74.4(2) applies to a transfer or loan of property ...

Income amount payable to a beneficiary

Tuesday, February 2nd, 2016

In many cases, amounts of trust income are allocated to the beneficiaries of the trust but the corresponding amounts are not actually paid. Instead, the trustees ensure that the amounts are due to the beneficiaries and such amounts are legally enforceable against the trust property. The Canada Revenue ...