Trace dividends through subsection 104(19), test connectedness for Part IV tax at the right moment, and avoid a surprise tax bill of nearly 40% of the dividend.
This course examines the legal and tax architecture of the trust sandwich structure, which involves a family trust positioned between an operating company and a holding company. It details the mechanical process of flowing dividends through the trust to a corporate beneficiary using subsection 104(19) of the Income Tax Act. The material highlights the critical importance of timing and connectedness tests, specifically addressing the implications of the Wefri Federal Court of Appeal decision. Participants will explore the risks associated with Part IV tax, the twenty-one-year deemed disposition rule, and anti-avoidance provisions like GAAR and TOSI. The content emphasizes the necessity of aligning legal documentation, tax filings, and transaction dates to avoid significant tax liabilities.
1 activity • 1 videos • duration: 54m
AJAG Professional Development was founded in 2003 with a mission of making professional development easier and more cost-effective for Canadian accountants and other financial advisory professionals. Our comprehensive range of flexible and reasonably-priced courses, programs and seminars are delivered online and in classroom-style settings in the Greater Toronto Area (Toronto, Oakville and Markham). AJAG features a roster of highly-qualified instructors who deliver content that is pertinent, up-to-date and engaging.
MTax, CPA
Mitra leads tax planning and compliance at McGovern Hurley, leveraging over 8 years of experience with firms like Deloitte, MNP, and Cadesky & Associates. Since joining in 2020, she has driven innovative tax strategies, led the Tax Insight and Research Committee, and delivered key corporate tax updates. Her expertise spans corporate restructuring, cross-border taxation, and high-net-worth planning, supported by her Master of Taxation from the University of Waterloo. Passionate about advancing tax knowledge, Mitra regularly mentors colleagues, conducts training sessions, and shares insights on emerging tax trends to help clients and teams achieve lasting success.
Provincial regulators of CPAs in Canada do not require that independent providers of CPD be approved to offer courses. Instead, individual CPAs are responsible for assessing whether a CPD activity meets their requirements, and may take activities from any source provided those requirements are met.
Every course offered on LearnFormula is delivered by a qualified subject matter expert or learning organization, and advances learning objectives that are relevant to the responsibilities or professional competencies of Canadian CPAs. All activities on LearnFormula are quantifiable in terms of hours, and are also verifiable, in that users receive documented evidence of their attendance via a certificate of completion after finishing a course (and this certificate is stored by LearnFormula indefinitely). Nearly 100,000 Canadian CPAs successfully satisfy their CPD requirements via LearnFormula on an annual basis.
