Section 85 vs Section 86 Rollovers: Tax-Deferred Restructuring for Canadian Businesses
michael Downie michael Downie

Section 85 vs Section 86 Rollovers: Tax-Deferred Restructuring for Canadian Businesses

Section 85 and Section 86 rollovers are essential Income Tax Act tools that let Canadian taxpayers transfer property or exchange shares without immediate capital gains tax. Ideal for incorporating sole proprietorships, estate freezes, or corporate reorganizations, these strategies preserve value through tax deferral while meeting CRA rules like T2057 filings.

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Avoiding Double Taxation on Private Company Shares: Pipeline Planning for Canadian Estates
michael Downie michael Downie

Avoiding Double Taxation on Private Company Shares: Pipeline Planning for Canadian Estates

Double taxation erodes Canadian estates when private company shares trigger capital gains at death followed by dividend taxes on distributions. This guide explains the problem with real examples and outlines CRA-approved solutions like pipeline plans—transferring shares to a NewCo for promissory note repayment—and expanded loss carryback rules allowing offsets up to three years post-death.

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