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The Advantages of Surplus Stripping and Disintegration – Section 84(2)

Surplus stripping is back in the news with recent changes to legislation.  This makes it imperative to understand past court decisions on this matter.  Surplus stripping allows a taxpayer to receive funds that that have been earned by a corporation and subjected only to the corporate tax rates, without paying the personal dividend tax rate. …

Act Now for Intergenerational Transfers – Bill C-208 Amendments to Section 84.1

There is still a window of opportunity for tax savings when transferring a business to a corporation owned by your child or grandchild and being allowed to claim the lifetime capital gains exemption before amendments are proposed to Bill C-208. Bill C-208 is a private member sponsored bill that allows small business owners to claim…

Splitting Income with Minor Children with Capital Gains Planning

Although income splitting with your children has become difficult, there is still some opportunities currently available that include using marketable securities, a Trust and a tax professional. Historically, income spitting was addressed through attribution rules.  These rules were circumvented through taxpayers winning court cases that established dividends were not attributable between shareholders (see Mcclurg v…