Bryant D. Frydberg

Partner | Calgary

403.298.2456

Portrait of Bryant D.  Frydberg

Half-Loaf Fully Baked?

In the recent decision Gervais v. R.[1], the Tax Court of Canada confirmed the application of the general anti-avoidance rule (“GAAR”) to a taxpayer who attempted to benefit from his spouse’s lifetime capital gain exemption.  The tax plan implemented is...

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“Half-loaf” Gone Wrong: Gervais, G. et al. v. The Queen (“Gervais”).

A recent case from the Tax Court of Canada ruled against a taxpayer who implemented a tax plan known as the “half-loaf” plan.  The purpose of a half-loaf plan is essentially to multiply the life time capital gain exemption between...

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Top Technical Bill Issues for Owners-Managers

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Recent Proposed Changes to Rules Applicable to Personal Services Business

Back in the 1970s, while the Montreal Canadiens were dominating the NHL, Ken Dryden backstopped the Canadiens to win six Stanley Cups. While much can be said about Ken Dryden’s heroics in winning the Stanley Cup, this is, after all,...

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Federal Budget Review 2013

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U.S. Tax and Filing Obligations for Canadians*

Canadian individuals are well aware of the April 30 tax filing deadline for Canadian income tax returns.  However, many Canadians may not be aware of the earlier April tax filing deadline of April 15 for United States tax purposes.  A...

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Federal Budget Review

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Employee Profit Sharing Plans – Changes to Come?

In the 2011 Federal Budget, the government announced its intention to review the rules regarding employee profit sharing plans (“EPSPs“). Further to this announcement, the Department of Finance issued a consultation paper on August 30, 2011 requesting feedback from stakeholders on...

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Tax Tip – Share Consideration Issued on a Tax-Deferred Rollover

Have you ever considered whether you can transfer eligible property on a tax-deferred rollover basis for consideration consisting of shares that have not been legally authorized under the articles of the transferee corporation at the time of the transfer? Recently,...

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International Tax: Corporate Residency – A New Approach to the Application of Central Management and Control

The recent decision of the Tax Chamber of the United Kingdom in Laerstate BV v. HMRC [2009] UKFTT 209 (TC) has caused a stir on both sides of the Atlantic ocean for those interested in corporate residency matters. While not...

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Donation of Exchangeable Shares

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Manitoba Tax Break for Hiring Co-op Students and Graduates

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Budget 2007 – Summary of International Tax Measures

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Tax Court Rejects Stamp Catalogue Valuation

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