Acquisitions of Control and the Effective Use of Corporate Losses
Nicholas P. Smith and Virginia Zhao
Acquisitions of Control and Effective Use of Corporate Losses
Read ArticleTransfers 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…
Read ArticleInternational 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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