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 ...

CAPITAL DIVIDENDS FROM A TRUST TO NON-RESIDENTS – TAX ISSUES

Tuesday, March 8th, 2016

Subject to the relevant sections of the Income Tax Act, a Canadian private corporation has a special corporate tax account known as a capital dividend account (“CDA”) which gives shareholders designated capital dividends, tax free. The CDA of a corporation may include the non-taxable portion of the company’s capital gains, ...