Personal Health Service Plans and Shareholder Benefits

“There could be shareholder benefits and non-deductible payments for PHSP’s..” In a recent case (Spicy Sports Inc.),…

Disassociating Companies

“Using a specified class of shares can disassociate companies..” There are many situations where two companies are…

Foreign Social Security Taxes As Foreign Tax Credits

“For countries other than U.S., the foreign social security taxes are no longer a tax credit..” The…

Single Purpose Corporations

“CRA has changed its administrative position for companies owning U.S. real estate..” In a recent Technical News,…

Loans To Family Members

“Certain conditions are necessary to claim capital losses on loans to family members..” There have been a…

Overpayment of U.S. Taxes May Prohibit Claim of Foreign Tax Credit

“Taxpayers must ensure that they only pay the withholding rate per the treaty.” In a recent tax…

Supreme Court Decision – Gifford

“This Supreme Court case is relevant for the purchase of intangible assets and interest deductibility.” On February…

Death Benefits

“Tax-free payments are permitted in certain situations..” There are few types of income which escape the grasp…

Subsection 75(2) – Planning To Avoid

“It is important to carefully draft trusts to avoid unwanted results.” Trusts can be a very useful…

Alternative To Alter-Ego Trusts

“Self Benefit trusts may help those under 65 in dealing with probate fees.” In our February 7,…

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