Estate and Charitable Gift Planning

Nicholas P. Smith and Stephanie Shi

Trusts are a useful tool for designing an estate plan that works within the constraints imposed by law and each client's unique set of circumstances. To view the full paper, click here.

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Acquisitions of Control and the Effective Use of Corporate Losses

Nicholas P. Smith

Acquisitions of Control and Effective Use of Corporate Losses

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Transfers to the Corporation: Section 85 Rollovers

Nicholas P. Smith

I.     INTRODUCTION S.85(1) of the Income Tax Act (Canada) (the “ITA”)[1] allows a person to transfer property to a taxable Canadian corporation on a tax-deferred basis.  This rollover allows a person to defer the recognition of income, capital gains…

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International and Interprovincial Tax Planning Issues for Individuals and Trusts

Nicholas P. Smith

I.     INTRODUCTION Planning for clients with assets and beneficiaries in multiple jurisdictions requires knowledge of residency and the deeming rules that could alter its common law meaning. The interprovincial source rules for the taxation of…

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