Tax planning for business succession - 2015

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This is the agenda for Module
Module Session
Module 1
Estate planning and orderly succession

• The consequences of no business succession plan
• Crystallization of the capital gains deduction
• Crystallization, paid-up capital, and deemed dividend
• Redemption of crystallized shares
• Basic planning — Insurance
• Modification for the lifetime capital gains deduction
• The subsection 40(3.6) estate exception
• 1998 Amendments

Module 2
Estate planning and orderly succession: Estate freeze

• Estate freeze
• Considering an estate freeze
• How to choose suitable provisions for the preferred shares issued on the freeze

Module 3
Income splitting and the attribution rules

• Income splitting: A non-business succession reason for freezing
• The attribution rules

Module 4
The use of trusts in tax planning

• What is a trust?
• Discretionary trusts for holding shares
• Taxation of trusts
• Taxation of beneficiaries
• The reversionary trust attribution rule
• Establishing the structure
• Miscellaneous advantages
• Miscellaneous problems

Module 5
Selected topics on business succession

• Reversing estate freezes
• Miscellaneous matters