Subection 110.6(8) does not apply if dividends are not paid on “prescribed shares”. An ordinary common share is a prescribed shares under Reg 6205(1). A “freeze share” is prescribed if it meets the requirements of Reg 6205(2). The authors note…
Are persons related to themselves?
When are persons related for the purposes of subparagraph 110.6(14)(c)(ii)? A person is not generally deemed to be related to himself except for certain purposes (paragraph 251(5)(c), subparagraph 55(5)(e)(ii), subsection 256(1.5) and determining whether corporations are associated). Compare this to…
Crystallizing and estate planning
Is it always a good idea to take full advantage of the capital gain exemption (CGE) by crystallizing? Assume Ms X crystallizes her Opco shares, but Opco morphs into an investment holding company by the time of her death. In…