Capital Gains Changes: Overview and Effective Tax Planning

Gain a detailed understanding of the new inclusion rates for different taxpayer groups and explore the broader implications for tax planning.

• Capital Gains Inclusion Rate Changes: Understand the implications of the increase in capital gains inclusion rate from 1/2 to 2/3 for corporations and trusts, and the tiered approach for individuals.
• Alternative Minimum Tax (AMT) Adjustments: Review how the AMT will interact with the new capital gains inclusion rate and its potential impact on high-income earners after June 25, 2024.
• Capital Gains Exemptions and Thresholds: Explore the adjustments to capital gains exemptions, including the increase to $1,250,000 and how this impacts tax transactions.
• Impact on Estate and Corporate Planning: Examine the implications for estate planning and corporate tax liabilities, focusing on changes to the capital dividend account and terminal tax obligations.
• Employee Stock Options and New Tax Limits: Analyze how the change in the capital gains inclusion rate will affect employee stock options, particularly with the introduction of a new combined limit of $250,000 affecting deduction eligibility.
• Corporate Strategies and the Principle of Integration: Discuss the principle of integration and how the new policy creates further under-integration and the resulting tax impacts.
• Navigating Complex Tax Changes: Provide guidance on managing the transition to the new rules, including the use of capital gains reserves and loss carryforwards under the altered tax landscape.

Employee Ownership Trusts

The participant will be able to:

• Understand the proposed employee ownership trusts (EOTs) and their taxability.
• Evaluate the tax advantages of EOTs in the context of Qualifying Business Transfers.
• Discuss with clients, the eligibility requirements of EOTs.
• Understand other EOT related tax issues such as shareholder loan rules and 21-year deemed disposition rule.

Integenerational Business Transfers

The participant will be able to:

• Provide an overview of the deemed dividend provision under Income Tax Act Section 84.1.
• Understand the genuine intergenerational transfer rules introduced by Bill C-208 and the Federal Budget 2023.
• Explore strategies for ensuring corporate shares meet QSBC eligibility criteria, with an emphasis on the importance of advanced planning.
• Evaluate the impact of alternative minimum tax on genuine intergenerational transfers.

General Anti-Avoidance Rule

The participant will be able to:

• Understand the origins of the changes - The Wild Case.
• Grasp the proposals outlined in the 2022 budget.
• Grasp the proposals outlined in the 2023 budget.
• Assess the impact of GAAR changes on our tax planning strategies for 2024 and beyond.