In Brianne Gwartz v. The Queen, 2013 TCC 86, the Crown attempted to utilize the GAAR to recharacterize as dividends certain capital gains which had been realized by a family trust and allocated to the minor-aged taxpayers in...more
Poor John Paulsen! Now that's an oxymoron! He has to be the most radioactive man on the Planet when it comes to tax planning. Everything he touches in business seems to be couched in subversive tax planning...more
As of April 1st, companies paying UK corporation tax can take advantage of a new tax regime, dubbed the “Patent Box,” to reduce their tax burden. Here we explain why this new regime has been put in place and how and why it...more
In the Provincial Income Allocation Newsletter No. 4 (March 2013), the Canada Revenue Agency notes that the Allocation Review Committee (“ARC”) has changed its position on amounts previously excluded in calculating “salary...more
Most everyone is aware that the United States Supreme Court heard two historic cases this week focused on same-sex marriage. One involves California’s Proposition 8 banning same-sex marriages (which was then rendered...more
Every financial media outlet (including Bloomberg and the Wall Street Journal) in the last several weeks has run an article on the possibility of billionaire hedge fund manager becoming a Puerto Rican...more
Donating life insurance to a favorite charity is an excellent opportunity to make a larger donation than may otherwise be affordable. This article shows why this is so and discusses the most tax-effective way to donate life...more
Originally published in Deal Points: The Newsletter of the Mergers and Acquisitions Committee - American Bar Association - Winter 2013.
When the seller of a business or the assets of a business is negotiating the scope...more
On January 16 the Internal Revenue Service (IRS) issued guidance on the application of the retroactive increase in excludible transit benefits, as enacted under the American Taxpayer Relief Act of 2012 (ATRA). IRS Notice...more
Originally published in the Journal of Taxation of Investments in December 2012.
This article is designed to provide an overview of the benefits of private placement life insurance (PPLI) and private...more
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