Archive for the ‘Loans’ Category

Redeemable Preference Shares: Accounting Proposal might complicate estate tax plans

Tuesday, December 2nd, 2014

Estate and succession planning arrangements often involve the creation of redeemable and retractable preference shares to “freeze” the value of a business to permit the transfer of the business’ future growth to designated successors. This is commonly found in estate planning arrangements for family owned businesses but it is also ...


Wednesday, May 7th, 2014

Recently, the Canada Revenue Agency (“CRA”) was asked if there was an advantage as defined in the Income tax Act (subsection 207.05(1) for those who care to look it up) in a situation where the annuitant of an RRSP trust which holds shares of a corporation uses an asset ...

Why Being Late With a Designation is Not so Good

Tuesday, March 25th, 2014

In certain circumstances, the Income Tax Act allows a trust to designate a portion of its net taxable capital gains as a taxable capital gain in the hands of a beneficiary of the trust. This allows the benficiary to use their available capital gain exemption to shelter the ...