tag:blogger.com,1999:blog-4402283548766807872.post5383277079883951426..comments2024-03-20T02:26:06.500-04:00Comments on The Blunt Bean Counter: Corporate Small Business Owners: Beware; the Capital Gains Exemption is not a GimmeThe Blunt Bean Counterhttp://www.blogger.com/profile/11358868550072516313noreply@blogger.comBlogger28125tag:blogger.com,1999:blog-4402283548766807872.post-46252134810300025002020-06-11T15:07:26.122-04:002020-06-11T15:07:26.122-04:00This comment has been removed by a blog administrator.alihttps://www.blogger.com/profile/11835830755852577356noreply@blogger.comtag:blogger.com,1999:blog-4402283548766807872.post-57969910174805023512017-11-10T13:13:56.108-05:002017-11-10T13:13:56.108-05:00Hi Marisha
Thx for reading. At this point until t...Hi Marisha<br /><br />Thx for reading. At this point until the Liberals issue actual legislation I would not be setting up any such structures. In addition, you should have any plans you create reviewed by a tax specialist.<br /><br />At the time of writing, the Holdco would be owned by the trust and the CGE would flow through the trust to the beneficiaries. The Blunt Bean Counterhttps://www.blogger.com/profile/11358868550072516313noreply@blogger.comtag:blogger.com,1999:blog-4402283548766807872.post-91296016398950952502017-11-09T13:45:57.864-05:002017-11-09T13:45:57.864-05:00Hi Mark!
I am an accountant myself and want to tha...Hi Mark!<br />I am an accountant myself and want to thank you for this amazing, informative blog :) I am about 4 years into my business and have been reading your blog for about 6 months now. Thank you! Question regarding the structure of Opco, Holdco and Family Trust. Would the shareholders of Holdco be the true individual business owners in this scenario (to access the CGE). <br />Thanks,<br />Marisha Marishahttp://www.mazurekbiz.comnoreply@blogger.comtag:blogger.com,1999:blog-4402283548766807872.post-70929824192420397032017-05-30T22:37:06.795-04:002017-05-30T22:37:06.795-04:00Hi Owen, you are selling shares of the company of ...Hi Owen, you are selling shares of the company of which one asset is a holdco or Holdco's. It could be possible on the look through rules that a holdco qualifies if it is just holding shares of an qualifying active companyThe Blunt Bean Counterhttps://www.blogger.com/profile/11358868550072516313noreply@blogger.comtag:blogger.com,1999:blog-4402283548766807872.post-15515382408146599142017-05-29T23:25:46.733-04:002017-05-29T23:25:46.733-04:00Hi Mark. I was reading your article above and it ...Hi Mark. I was reading your article above and it is VERY helpful. I have 1 question relative to the Holding Companies section. In #2, you say that can be problematic to hold several corps under your Holdco if you want to sell one of them. you then talk about be offside of the QSBC. But if the holdco owns Corp A, B and C, what difference does the QSBC make when you sell Corp A? The holdco doesn't qualify for the QSBC exemption anyway? Does it? Thank you and have GRRRRRRRRRREAT day! ....Owen The Mad Accountanthttps://www.blogger.com/profile/12717671105957688697noreply@blogger.comtag:blogger.com,1999:blog-4402283548766807872.post-15658326428893553352017-01-25T16:12:12.317-05:002017-01-25T16:12:12.317-05:00Anon as noted above this area is super complex. Th...Anon as noted above this area is super complex. The timing may or may not matter depending upon what you are trying to accomplish. Speak to your accountantThe Blunt Bean Counterhttps://www.blogger.com/profile/11358868550072516313noreply@blogger.comtag:blogger.com,1999:blog-4402283548766807872.post-32325937059941085152017-01-25T12:09:35.609-05:002017-01-25T12:09:35.609-05:00Hi Mark,
Are there any timing requirements as to w...Hi Mark,<br />Are there any timing requirements as to when the purification of a SBC is done prior to a freeze and introduction of a family trust?Anonymousnoreply@blogger.comtag:blogger.com,1999:blog-4402283548766807872.post-73029393270162296202017-01-12T21:56:05.558-05:002017-01-12T21:56:05.558-05:00Hi Anon
There is no minimum. You are mixing up co...Hi Anon<br /><br />There is no minimum. You are mixing up concepts. The 10.1% is so the Holdco is connected and can receive intercorporate dividends tax freeThe Blunt Bean Counterhttps://www.blogger.com/profile/11358868550072516313noreply@blogger.comtag:blogger.com,1999:blog-4402283548766807872.post-6067314580213295862017-01-12T16:15:30.201-05:002017-01-12T16:15:30.201-05:00Hi Mark,
Is there any rule (in AB maybe?) where th...Hi Mark,<br />Is there any rule (in AB maybe?) where there is a minimum number of shares a Holdco MUST purchase of an Opco to actually exist? Someone's told me that you MUST own at least 10.1% of the Opco's shares to open a Holdco. Love the blog, by the way...Anonymousnoreply@blogger.comtag:blogger.com,1999:blog-4402283548766807872.post-82467875006452537032016-11-08T14:43:08.433-05:002016-11-08T14:43:08.433-05:00Hi Anon
There is no such rule, you may be thinkin...Hi Anon<br /><br />There is no such rule, you may be thinking of the more than 5 employee rule for specified investment income, but that is just a deeming rule for claiming the small biz deduction, it has nothing to do with the QSBC status for the capital gains exemption.The Blunt Bean Counterhttps://www.blogger.com/profile/11358868550072516313noreply@blogger.comtag:blogger.com,1999:blog-4402283548766807872.post-45184684083405964622016-11-08T14:22:20.905-05:002016-11-08T14:22:20.905-05:00Hi Mark,
I heard something about a rule regarding ...Hi Mark,<br />I heard something about a rule regarding a stress test of how many employees the company has in order to qualify. Have you heard of that?Anonymousnoreply@blogger.comtag:blogger.com,1999:blog-4402283548766807872.post-53907854085543216822016-10-19T20:52:27.252-04:002016-10-19T20:52:27.252-04:00Hi Gabe:
There is probably some value in the comp...Hi Gabe:<br /><br />There is probably some value in the company at this point, so you cannot just issue new Class C shares at nominal value and trying to override the dividend rights of the common shares are problematic. You need to speak to your accountant or engage one to determine the best course of action as there are many other factors to consider.The Blunt Bean Counterhttps://www.blogger.com/profile/11358868550072516313noreply@blogger.comtag:blogger.com,1999:blog-4402283548766807872.post-62209741272684523252016-10-19T13:36:50.175-04:002016-10-19T13:36:50.175-04:00Hi Mark,
I have a OpCo right now for a year in SK...Hi Mark,<br /><br />I have a OpCo right now for a year in SK, with myself owning 100 Class A common voting and my wife owning 100 Class B common non-voting. There is a bit of retained earnings after year one. <br /><br />If I were to introduce a HoldCo, could I get the HoldCo to own Class C common shares and then issue a class specific dividend back up to HoldCo for creditor proofing?Commissioner Gabehttps://www.blogger.com/profile/00145327006282776978noreply@blogger.comtag:blogger.com,1999:blog-4402283548766807872.post-92136850241943953392016-08-14T21:13:59.238-04:002016-08-14T21:13:59.238-04:00Thx AnonThx AnonThe Blunt Bean Counterhttps://www.blogger.com/profile/11358868550072516313noreply@blogger.comtag:blogger.com,1999:blog-4402283548766807872.post-42829573521264373602016-08-13T11:28:10.774-04:002016-08-13T11:28:10.774-04:00Hello Mark,
You are good.
You should publish a boo...Hello Mark,<br />You are good.<br />You should publish a book:<br />"QSBC Purification and Such"<br />a plain English version of our murky ITA<br /><br />If I had paid $2500 for such a book, it would still have been way cheaper that what it cost me to understand up to just what you explain in the above article.<br />Thank you for publishing.Anonymousnoreply@blogger.comtag:blogger.com,1999:blog-4402283548766807872.post-8162370699998431192015-12-18T16:10:54.801-05:002015-12-18T16:10:54.801-05:00Off the top of my head, it would not qualify for a...Off the top of my head, it would not qualify for a replacement property, but I have not researched it. Speak to your accountant, I don't do other accountants planning on this blogThe Blunt Bean Counterhttps://www.blogger.com/profile/11358868550072516313noreply@blogger.comtag:blogger.com,1999:blog-4402283548766807872.post-38163776860112425322015-12-17T16:52:29.475-05:002015-12-17T16:52:29.475-05:00Thanks Mark for your reply. I search on internet a...Thanks Mark for your reply. I search on internet and came to know about "replacement property rules" and wondering if it is possible that I purchase my new home again on the holdco and declare sale as replacement property. In this way I may defer the immediate capital gain.Anonymousnoreply@blogger.comtag:blogger.com,1999:blog-4402283548766807872.post-58666405169524129722015-12-16T17:52:04.301-05:002015-12-16T17:52:04.301-05:00Hi Anon
Your accountant is correct, you cannot us...Hi Anon<br /><br />Your accountant is correct, you cannot use your capital gains exemption on passive investments such as real estate. I always steer my clients away from owing their home in a corp for many reasons, including the fact once you put it in a corp, it is no longer tax free because you lose the principal residence exemption and cannot claim the capital gains exemption, let alone the taxable benefits you incur having ur home in a corp.The Blunt Bean Counterhttps://www.blogger.com/profile/11358868550072516313noreply@blogger.comtag:blogger.com,1999:blog-4402283548766807872.post-26101372563597843562015-12-16T13:56:30.971-05:002015-12-16T13:56:30.971-05:00Hi Mark,
I have purchased my residential house on ...Hi Mark,<br />I have purchased my residential house on Holdco. now I want to sell my house but my Accountant shocked me that large tax is payable by Holdco because the house price is appreciated. If I cannot use my LGE?Anonymousnoreply@blogger.comtag:blogger.com,1999:blog-4402283548766807872.post-34942516624842471852015-12-12T11:41:48.619-05:002015-12-12T11:41:48.619-05:00Thank you.Thank you.Anonymousnoreply@blogger.comtag:blogger.com,1999:blog-4402283548766807872.post-49170829415992201902015-12-02T13:42:50.736-05:002015-12-02T13:42:50.736-05:00Hi David
Sorry, but I don't answer technical ...Hi David<br /><br />Sorry, but I don't answer technical questions on this blog. Ask your own accountant or engage one for questions such as this.The Blunt Bean Counterhttps://www.blogger.com/profile/11358868550072516313noreply@blogger.comtag:blogger.com,1999:blog-4402283548766807872.post-37147340182217302692015-12-02T11:57:37.018-05:002015-12-02T11:57:37.018-05:00110.6(14)(f)(ii) what happens if a taxpayer wants ...110.6(14)(f)(ii) what happens if a taxpayer wants to roll only part of his customer list (say 33%) from a sole proprietorship to a corporation under s85 and sell the corporation and use the CGE . Does this section disqualify the shares because 90% of his list is not transferred? David Smithhttp://dsmithca.googlepages.com/homenoreply@blogger.comtag:blogger.com,1999:blog-4402283548766807872.post-67639190851363313692015-03-18T23:27:55.523-04:002015-03-18T23:27:55.523-04:00Hi Nick
Sorry, I do not provide personal tax plan...Hi Nick<br /><br />Sorry, I do not provide personal tax planning advice on this blog. There are complicated look through rules for Holdco's, you should speak to your accountant.The Blunt Bean Counterhttps://www.blogger.com/profile/11358868550072516313noreply@blogger.comtag:blogger.com,1999:blog-4402283548766807872.post-13347184384750288842015-03-18T14:54:26.438-04:002015-03-18T14:54:26.438-04:00Hi Mark,
Here is a situation and perhaps you can ...Hi Mark,<br /><br />Here is a situation and perhaps you can help me:<br />I have held my shares of my holdco (operates as a small active company)for over 10 years. My holdco has also owned 1/3 of an Opco and have held those opco shares for 7 years. My holdco recently bought (Jan 2015) the other 2/3 shares of Opco (unrelated to me) so now we hold 100% of Opco. If I happen to get a good deal for someone to buy my holdco shares this summer will I be entitled to the capital gain exemption?<br /><br />Someone tells me my holdco had to have owned the other 2/3 Opco shares for at least 2 years. I'm not sure if this is correct.<br /><br />Nick Nicknoreply@blogger.comtag:blogger.com,1999:blog-4402283548766807872.post-35704064139402257762014-09-25T17:19:09.768-04:002014-09-25T17:19:09.768-04:00I will check it out, I have no idea. I will check it out, I have no idea. The Blunt Bean Counterhttps://www.blogger.com/profile/11358868550072516313noreply@blogger.com