Tax Notes

July 2014

Displaying 1-4 of 4

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

Bryant D. Frydberg

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...

More

Current Changes to Testamentary Trusts and Continuing Advantages

Andrea Lamy, William J. Fowlis

The 2014 Federal Budget proposes to introduce a number of significant changes to the taxation of trusts and estates which will fundamentally change the landscape of estate planning. The Department of Finance (the “Department”) proposed these changes to eliminate the...

More

What’s Happening at Miller Thomson

Speaking Engagements Rachel Blumenfeld, TEP, of our Toronto office moderated a panel discussion “Cross-Border Planning: Tax Traps and Mismatches” at the Society of Trust and Estate Practitioners (Canada) National Conference on June 17, 2014. Rosanne Rocchi, LLM, TEP, of our...

More

Rectification: Current Developments Regarding This Useful Judicial Remedy

Lesley M. Akst

Rectification is an equitable remedy that allows for judicial corrections of a document that, due to errors in drafting, does not reflect the true intentions of the parties. Rectification changes a document’s mistaken expression of that intention. Rectification is restorative,...

More

Displaying 1-4 of 4