SHARES ISSUED FOR NOMIMAL CONSIDERATION: BE WARY OF VALUATION

Tuesday, June 28th, 2016

Recently, the Canada Revenue Agency (“CRA”) was asked to comment on the tax consequences that may result from implementing an estate planning or income splitting arrangement which involves the issuance of shares that entitled the holder to discretionary dividends, for nominal consideration. The CRA was presented with a hypothetical small business ...

INCOME FROM A U.S. TRUST: CAN IT EVER BE TREATED AS DIVIDEND INCOME?

Tuesday, June 14th, 2016

Sometime ago, a relative of a Canadian taxpayer died in the US and she left her money in a charitable trust, with some of the income bequeathed to the Canadian taxpayer annually. The trust income is derived mostly from US dividends. With a series of proposed adjustments to her personal tax ...