Tax Planning For Amalgamations, Reorganizations and Wind-ups
Many clients are not aware that subsection 160(1) of the Income Tax Act imposes joint and several liability for tax on certain transfers of property between persons who do not deal at arm's length with each other. Both the transferor and the transferee can be held jointly and severally liable for the transferor’s taxes. There are several types of defences that Our Team has effectively used to help clients in dealing with the CRA regarding subsection 160(1) assessments. To access Part 3 of our latest Legal Business Report in this area, click here.
Alpert Law Firm are the Tax Law Professionals, with over 40 years’ experience in winning leading cases and a reputation for getting excellent results for your clients. Howard Alpert, C.S. is certified by the Law Society as a Specialist in Taxation Law. Vivian Xu, B.A. J.D. is an associate lawyer specializing in tax dispute resolution, tax litigation and taxation and estate planning services. Our Team has superior case management skills and achieves the most favourable resolution of disputes for our clients, whether through negotiating timely and reasonable settlements or by vigorous representation in court. For more information on our Tax Dispute Resolution services, click here.
Avoid Liability for Non-Arm's Length Property Transfers
When entering into a share purchase transaction, many clients are not aware that there are additional tax planning considerations regarding non-resident vendors, earnout agreements and section 88 wind-ups. There are significant implications regarding the issuance of a section 116 Clearance Certificate for a share sale by a non-resident vendor. To read Part 2 of our latest Legal Business Report on this topic, click here.
Alpert Law Firm are specialists in share purchase transactions. Howard Alpert, C.S. has been certified by the Law Society as a Specialist in Corporate and Commercial Law and as a Specialist in Taxation Law. Our Team designs plans to assist our clients in minimising and deferring taxes in a cost-effective manner. For more information, click here.
Freeze the Taxman Out of your Estate
Asset protection planning often involves the creation of holding companies, a corporate reorganization and the implementation of an estate freeze. Such planning regularly requires the preparation of wills, trusts, powers of attorney, living wills and property transfers. Howard Alpert, C.S. is certified by the Law Society as a Specialist in Taxation Law and as a Specialist in Corporate and Commercial Law and is recognized as an expert in Estates and Trusts Law. Howard provides tax planning and corporate advice to develop plans that reduce and defer tax, preserve value and maintain the financial well-being of heirs. For more information on our Wealth Preservation services, click here.