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

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.