Section 160 & CRA Rulings of Interest | January 2013

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Please join David M. Piccolo and Vitaly Timokhov for our next installment:

In this webinar, David and Vitaly will discuss:

• A Review of Section 160 Assessments
• CRA Administrative Positions & Rulings of Interest

David presents on section 160 assessments, how it assists the CRA in collecting on tax debts, what happens in situations when transferees are not at arm’s length, what sort and when is consideration considered to have been received, de facto control, joint and several liability, the general lack of a limitation period when assessed under section 160, what happens with interest, and the rough equivalence of section 325 of the Excise Tax Act to that under the Income Tax Act.

Vitaly Timokhov presents on pipeline strategies, post-mortem tax planning to prevent double or triple taxation, corporation-trust sandwiches to produce double non-taxation situations, section 84.1 and GRIP on deemed dividends, the windup of a corporation, the deemed disposition of assets at FMV on death, the subsection 84(2) dividend on the discontinuance of a business, reorganization of business, PUC concerns, the capital dividend account, dividend stripping through trusts, GAAR, subsection 75(2), and the attribution of trust income to settlor, select anti-avoidance rules.