Assume , for example , that a taxpayer transfers capital property having an original cost of $ 20 , a V - day value of $ 100 , and a value of $ 140 at the time of the transfer in return for common shares of the transferee corporation .
Trusts are often used to own new shares of a corporation issued upon an estate freeze for the benefit of the freezor's children ... Readers are referred to David Louis , “ Implementing Estate Freezes ” , ( CCH Canadian Limited : Toronto ...
Report of Proceedings of the Tax Conference Convened by the Canadian Tax Foundation
The tax planning area of estate freezing has been alluded to in previous discussions of the advantages of the use of ... The implementation of an estate freeze may coincide with planning to split income with low tax-rate family members, ...
University of Miami Institute on Estate Planning ... 1604.1 Qualified terminable interest property trust distributions according to ascertainable standard . ... D Estate freezes, implementing . . . . 604.3.C.1; 604.3.
( 3 ) The individual who transferred or loaned the property must be a resident of Canada during the relevant period . ... is reduced if there is considera6 On the subject of estate freezes , see David Louis , Implementing Estate Freezes ...
Section 86 Freeze In a section 86 freeze , the parent would exchange his or her operating company shares for preferred shares having attributes ... It is often convenient to do so in the course of implementing an estate freeze .
Recent Developments in Estate Planning and Administration
Taxation and Estate Planning
Every Family's Business: 12 Common Sense Questions to Protect Your Wealth