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Internal and Holding Company Freezes
Corporate Estate Freezes Technical Issues
Alternative Methods and Variations
Capitalization Considerations and Share Provisions
A Case Study
acquired addition adjustment affiliated agreement allow amended amount apply assets attribution rules basis beneficiaries benefit Canada Canadian capital gains capital property circumstances Class clause common shares consideration considered continue corporation cost base course court death deduction deemed determined discretionary discussion disposition distribution dividend effect election eligible equal estate freeze example exchange exemption fact fair market value family trust filed freeze shares gains growth held holding Hoots-Paw income income tax increase individual interest investment involved issue Larry length limited loss means noted otherwise paid paid-up capital paragraph particular partnership person planning possible preferred preferred shares provisions purchaser pursuant reasonable received redeemed redemption reorganization respect restrictions result retraction rules section 85 shareholders situation specific spouse subsection 75(2 taxable taxpayer Technical tion transaction transfer transferor trust voting