Tax Implications of Inter-company Transactions in a Closely Held Group - Filmed in 2019

Course Price: $175.00

Number of PD hours: 3.0

Online - Recorded - Available

Topics will include:

  • Historical treatment of intercompany fees.
  • Judicial support for intercompany fees - the Safety Boss case.
  •  The personal service business rules.
  • HST issues.
  • Comparison of the income sources previously eligible for the small business deduction and the sources now eligible.
  • Changes to the S.256(2) election to disassociate corporations.
  • Corporate partners; old rules versus new rules – non-partner corporations deemed to be partners under the new rules.
  • Assignment of entitlement to the small business deduction by a partner that pays a fee or other amount to the recipient – S.125(8).
  • Anti-avoidance rules.
  • Assignment of entitlement to the small business deduction by the payor of a fee or other amount to the recipient – S.125(3.2).
  • Exemption from the new rules where the intercompany transactions are between associated corporations – S.125(10) – and the limitations to the exemption.
  • Management companies and new rules.

Instructor

Perry Truster FCPA, FCA