BEWARE OF HIDDEN TAX CONSEQUENCES

Friday, February 12th, 2016

A recent Alberta Court of Queen’s Bench decision in Morrison v. Morrison 2015 CarswellAlta 2249 (Alta.Q.B.) reminds advisors and clients alike of (i) the need to consider the income tax consequences of not only their overall estate plan, but components within it, and (ii) the importance of stating intention expressly ...

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 ...