Section 84.1 Anti-Avoidance Explained — Canada 2026
Section 84.1 prevents converting dividends to capital gains by selling shares to related corps. Bill C-208 intergenerational exception. LPA-led tax planning.
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Intercorporate Dividend Rules Canada — Section 112 & 113 (2026)
Section 112/113 intercorporate dividends, Section 55(2) anti-avoidance, safe-income tracking. Tax-free flow between connected Canadian corps. CPA review.
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Holdco vs Opco — When You Need a Holding Company in Canada 2026
Decision guide for Ontario owner-managers. When does adding a Holdco above your Opco pay back? Cost, benefits, when to skip. CPA, CA, LPA review.
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Section 88 Winding-Up Canada — Bumping Cost Base 2026
Section 88(1)(d) wind-up of a wholly-owned subsidiary into the parent. Tax-free transfer. Bump cost base of capital property up to FMV. LPA-led, $10K-$35K.
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Estate Freeze Ontario — Section 86 Mechanics 2026
Section 86 estate freeze step-by-step. Lock in today’s value, pass future growth to kids or family trust. Valuation, share class, $15K-$50K fixed fee. LPA-led.
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Section 85 Rollover Canada — Worked Example for Owner-Managers
Step-by-step Section 85 rollover with worked example. Form T2057 election, elected amount, boot, share consideration. CPA, CA, LPA-led rollovers $7,500-$25,000.
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Multi-Project Developer Year-End Tax Checklist 2026
11-point year-end tax checklist for GTA developers running 2-7 projects. WIP valuation, holdback receivables, Section 13(21.
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Capital vs Income on Real Estate Sales
When does CRA reclassify your real-estate gain as business income? Six factors per Folio S3-F4-C1. Defense documentation for Ontario developers and investors.
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HST New Housing Rebate for Developers Canada 2026
Step-by-step GST/HST New Housing Rebate (NHR) and NRRP Rebate for GTA developers. Federal + Ontario portions, GST190 vs GST524, builder vs buyer claim, audit.
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TOSI for Ontario Doctors 2026 — Family Splits That Survive
Tax on Split Income (TOSI) for incorporated Ontario doctors. Excluded business, excluded shares, age 65+, reasonable return exceptions. What survived 2018.