In advance of a sale of a business it is common for clients to undertake a reorganization to ensure that the transaction is being done in the most tax efficient manner. This course will review some of the common strategies used.
Topics to be covered will include:
- Incorporating a business prior to sale
- Incorporating a partnership prior to sale
- 55(3)(a) reorganizations
- Safe-income planning
- 111(4)(e) planning
Marni Pernica LL.B & Edward Miller LL.B
Marni Pernica LL.B
Understanding both the financial and personal elements of a family is essential to ensuring that a client’s estate plan reflects their unique circumstances. Marni works closely with her clients to provide them with practical, thoughtful advice regarding their estate plan.
Clients appreciate Marni’s strong relationship-building skills and reputation as a thought-leader, and trust her because they are comfortable confiding in her and confident in her ability to advise them effectively. As Co-Practice Group Leader of the firm’s Tax Group and Estates & Trusts Group, and a member of the Estates & Succession Planning Group, Marni’s practice focuses on estate, income tax and succession planning, including cross-border planning, planning to reduce estate administration tax (formerly known as probate fees), the preparation of wills, powers of attorney and trusts, and assisting with estate administration. Additionally, Marni advises clients on how to reduce personal and corporate tax, including the effective use of a family trust.
Marni offers thoughtful and effective planning for clients ranging from young families who are just starting out to multi-generational families who are looking for effective ways to transition assets to the next generation. Marni enjoys navigating the complexities that arise in complicated and layered family structures, such as the dynamics that are present in blended families. Marni also has significant experience with cross-border planning for clients who have U.S. or other foreign connections.
Marni frequently writes and speaks on topics involving tax, estate planning and business succession planning for audiences such as insurance and financial advisers, accountants, professionals, and fellow lawyers.
Edward Miller LL.B
Edward draws on his technical expertise and strong business acumen to deliver strategic tax insight to domestic and international clients. Whether providing corporate or personal tax planning advice, Edward's primary focus is on achieving his clients' objectives.
Edward is a member of the firm's Tax Group. He provides advice on domestic and international corporate tax planning as well as personal tax planning for owner-managers and high-net-worth individuals.
Prior to joining Aird & Berlis, Edward was a tax partner at a large international law firm. In this role, Edward advised on all areas of Canadian domestic and international income tax law, with a particular focus on investment funds, including exchange-traded funds, closed-end investment funds, mutual funds and offshore funds. He also advised on mergers and acquisitions, corporate reorganizations, public financings and private placements of equity, debt securities and subscription receipts.
Edward is recognized as a leading lawyer in Tax Law by The Best Lawyers in Canada.View Full Profile