Topics include:
Association
• Tax implications of being "associated"
• Who is "associated" for income tax purposes?
• Basic rules of association
• Advanced rules of association
3rd corporation rule, election
Specified class shares
Shares held by corporations, partnerships, trusts, minors
• Control
Legal ("de jure") vs. factual ("de facto")
Simultaneous
Control by group
Control by value
• Examples of application - various scenarios
• Recent developments in association
SBD grind due to AAII
SR&ED expenditure limit
CCA immediate expensing limit
General Rate Income Pool (GRIP)
• What is integration? How does it work?
Why are dividends "eligible" and "non-eligible"?
• What is GRIP and why does it exist?
• How is GRIP calculated?
Formula
Example - GRIP computation
• GRIP anomalies in Ontario
26.5% (actual) vs. 28% (expected) provincial tax rate
Impact of AAII rules - federal but not provincial
Refundable Dividend Tax on Hand (RDTOH)
• What is RDTOH and why does it exist?
• How is RDTOH calculated?
Refundable Part I tax on AII
Part IV tax on "portfolio" dividends
Part IV tax on "connected" dividends
Example - RDTOH computation
• New RDTOH regime - 2 is better than 1?
Purpose of the new regime
ERDTOH
NERDTOH
Dividend refund
Example - ERDTOH & NERDTOH computation