REVERSIONARY/REVOCABLE TRUSTS A trust is a relationship under which a person, called a settlor, contributes cash or other property in trust for the benefit of others, called the beneficiaries. The trust is not a legal person or entity for most purposes, but it is considered a “person” and a “taxpayer” for income tax purposes. The […]
ASSOCIATED CORPORATIONS Under the Income Tax Act, there are various rules pertaining to relationships between taxpayers, including individuals, trusts, and corporations. For example, there are rules that apply to “related” persons, “non-arm’s length” persons, “affiliated” persons, and “associated” corporations. The rules are generally restrictive in nature, and the tax policy reasons for the rules are […]
PROPOSED LUXURY TAX ON EXPENSIVE CARS, BOATS AND PLANES The Liberal government is planning to introduce a new Luxury Tax, to take effect on January 1, 2022. It will apply to: new cars, SUVs and pick-up trucks costing over $100,000 boats costing over $250,000 certain aircraft costing over $100,000 The tax will be 20% of the […]
HOW OPTIONS ARE TAXED An option to purchase a property, as the term implies, provides the holder of the option an optional right to purchase the property. The option is referred to as a call option. The purchase price under the option is sometimes called the exercise price or strike price. Conversely, an option to […]
DEATH AND TAXES You’ve heard the saying about this − there are two sure things in life. On top of that, when you die, there may be additional income tax payable owing to the “deemed disposition” rules and other rules that apply specifically upon death. Before we get to those issues, in the year of […]
TRANSFERRING SHARES TO AN RRSP Should you transfer shares that you already own to your RRSP? The prospect can be attractive. The shares you transfer are considered a contribution to your RRSP. If you have unused RRSP contribution room, you can thus get a substantial tax deduction for shares that you already own. If […]
Until recently, it was more financially beneficial to sell a business to a third party in Canada, rather than passing it along to children or grandchildren through an intergenerational business transfer. This had been a longstanding bone of contention among entrepreneurs. Bill C-208, An Act to amend the Income Tax Act (transfer of small business […]
NON-ARM’S LENGTH PROPERTY TRANSFERS Overview There are special rules under the Income Tax Act (the “Act”) that apply to property transfers to a non-arm’s length person. The rules, discussed below, can override the actual proceeds or sales price received on the property transfers. For most purposes, “related” persons, as defined in the Act, are non-arm’s […]
BUYING PROPERTY FROM A NON-RESIDENT If you are buying real estate — such as a house or condominium, or a commercial property — from a non-resident of Canada, you need to know about your obligation to withhold tax unless the vendor provides you with a “section 116 certificate” from the Canada Revenue Agency. A non-residents […]
ESTATES AND THE “PIPELINE” STRATEGY When a person dies, they are deemed to dispose of most of their capital properties at fair market value. This deemed disposition may trigger capital gains or losses, depending on the tax cost of the properties relative to their current fair market value. The person who acquires the property as […]
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