Blog Articles

Managed Risk; Reduced Tax Burden: Peace of Mind.

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Large yachts between rocky islands in Killarney or near Georgian Bay. A stock photo on themes of vacation, luxury, retirement, wealth, nature.

Notes on US Based Asset Protection Trusts

The following notes are not meant to be comprehensive with respect to Asset Protection planning. After considering what Asset Protection provisions exist in the... Read on.
Two Adirondack chairs on a wooden dock overlooking a calm lake, beautiful landscape of mountain lake, vacation in the mountains, luxury autumn vacation concept. Perhaps an estate and wealth planning themed stock photo.

Notes on Ontario Asset Protection Legislation

1. Creditor Protection Legislation in Ontario is centered on Insurance and RRSP’s. 191. Insurance Act (1) An insured may in a contract, or by a declaration other... Read on.
Aerial view large cruise ship sailing across a blue sea. View from a drone. A luxury and wealth themed stock photo..

Asset Values, Derivatives and Tax Planning

Income tax statutes often make use of fair or arms length consideration tests to distinguish legitimate transactions between related parties and illegitimate... Read on.
Aerial view of South Orange County's Laguna Niguel, California, a residential area with nice properties, palms, swimming pools, in the U.S. A wealth themed stock photo.

US Tax Compliance Issues

Disclosure requirements for U.S. tax residents is extensive and failure to comply can result in significant penalties. Non Residents who inadvertently become US tax residents via the... Read on.
Panoramic view of a large putting green on a Palm Springs, California Golf Course. A wealth and leisure themed stock photo.

Permissible Surplus Strip

With the ongoing increases to dividend tax rates, its worthwhile to review the possibility of removing funds from a corporation at capital gains rates. Pursuant to section 84.1 “hard ACB” is derived... Read on.
Adirondack and lounge chairs sitting on a wooden dock facing a calm lake during a sunny summer day. Sailing boats are tied to the dock. A stock photo.

Asset Protection and US Real Estate

Have you heard about the Florida homestead exemption and wished you could enjoy that level of security? It may not be out of reach; owning Florida property through a Florida LLC or... Read on.
Aerial view of expensive residential houses in island small town Boca Grande on Gasparilla Island in southwest Florida. American dream homes as example of real estate development in US suburbs. A stock photo.

Notes on Foreign Holding Companies

Canada’s concept of tax residence for legal entities while potentially posing difficulties for tax avoidance schemes (see Garron) could create some opportunities for asset protection planning in... Read on.
Aerial view of a jet ski at sea, tropical or Florida summer vacation or second home life style. Vacation, retirement or estate planning inspiration theme stock photo.

Children Attending University Abroad

Do you have adult children attending University abroad? If that child had plans to continue to work abroad after completing university, he/she could legitimately file... Read on.
Nice looking area for some real estate. Aerial view of Longboat Key town and beaches in Manatee and Sarasota counties along the central west coast of the U.S. state of Florida. A stock photo.

A Homestead Exemption for Canadians?

Florida (and a number of other US states) permit spouses to own property as Tenants by the Entirety (TE); a form of ownership based on the principal that... Read on.
Yachts moored on canal against cloudy sky at sunset in Las Olas Boulevard, Fort Lauderdale. A wealth themed stock photo.

Avoiding s. 256 Association Rules

The 25% cross ownership requirement of s. 256 refers to beneficial ownership; with control of a Corporation residing in a Trustee, ownership of shares can reside with the trust beneficiaries... Read on.