Shareholder-Manager Remuneration and Tax Planning for the Owner-Manager Assignments | Online Assignments Services

ASSIGNMENT 2 – Chapter 13
3 Problems x 10 points = 30 Points Total.
Problem 1 – Tax On Split Income (TOSI) 10 Points
LauCo carries on an active business supplying parts to an auto parts manufacturer. The sole shareholder of LauCo is Holdco. The shareholders of Holdco are Parent A, Parent B, Child 1 and Child 2. Parent A, Parent B, Child 1 and Child 2 each owns a separate class of shares of Holdco. Parent A is the founder of Opco’s business and is the controlling shareholder of Holdco.

• Child 1 is age 23 and is a full-time graduate student at a university and is away from home for most of the year either attending classes during the school term or working part-time as a research assistant during the summer. Child 1 has never performed any functions for Holdco or Opco and has not made any other contribution to Holdco or Opco and its business.

Don't use plagiarized sources. Get Your Custom Essay on
Shareholder-Manager Remuneration and Tax Planning for the Owner-Manager Assignments | Online Assignments Services
Just from $13/Page
Order Essay

• Child 2 is age 16 and is a high school student.
• LauCo pays a dividend to Holdco. Holdco declares and distributes a dividend on the class of shares held by Child 1 and Child 2.
Please write an email to your tax client describing the implications of the 2018 TOSI rules and Kiddie Tax on the dividend income received by Child 1 and Child 2. Although income splitting is greatly restricted as a result of the expanded TOSI rules, there are some exceptions which still allow individuals to benefit from income splitting with family members. In your email, be sure to discuss the TOSI exclusions pertaining to “business”, “shares”, and “ labour or reasonable return.”
Problem 2: QSBC and Capital Gains Exemption – 10 Points
Part A: Describe the three tests to qualify as QSBC share status and identify the tax implications and tax planning considerations of qualifying for QSBC (consider passive income limitations).
Part B: Do problem 13-2 (“ Karen would like to know whether, if she sold her shares of Cyber Corp, she would be able to claim the capital gains exemption on the sale. If they do not qualify for the CGE then she wants to know if there is anything that can be done to qualify?”)


Problem 3: Tax Planning versus Tax Evasion: General Anti Avoidance Rule ITA 245.
10 Points
Canadian law has a long-standing and firmly held principle upholding an individual’s right to tax planning. This is known as the Westminster Principle. This principle states that a taxpayer is entitled to arrange his or her affairs in such a way that results in the lowest amount of taxes payable.
The anti-avoidance provisions in the Income Tax Act are intended to prevent taxpayers from structuring a transaction solely to achieve a tax benefit. The GAAR can invalidate a transaction if the Court decides the transaction or a series of transaction were made with the sole purpose of achieving a tax benefit. Consequently, the application of GAAR by Canadian judges has led some taxpayers to question the extent to which tax minimization is possible. The Supreme Court of Canada has set out a three-part test to determine whether or not to apply the GAAR:

1. Whether there is a tax benefit arising from a transaction;
2. Whether the transaction is an avoidance transaction “arranged primarily for bona fide purposes other than to obtain the tax benefit”; and
3. Whether the avoidance transaction is abusive.

Required:
Please find a recent example of a Canadian GAAR ruling. Summarize the case using the definitions provided under ITA section 245, the GAAR application logic in your textbook, and/or other reputable sources (e.g., tax court rulings, common law, business ethics theories etc…). Please state your position in support or against the ruling with supporting reasoning. Be sure to reference all relevant citations.

Acme Writers
Calculate your paper price
Pages (550 words)
Approximate price: -

Why Work with Us

Top Quality and Well-Researched Papers

We always make sure that writers follow all your instructions precisely. You can choose your academic level: high school, college/university or professional, and we will assign a writer who has a respective degree.

Professional and Experienced Academic Writers

We have a team of professional writers with experience in academic and business writing. Many are native speakers and able to perform any task for which you need help.

Free Unlimited Revisions

If you think we missed something, send your order for a free revision. You have 10 days to submit the order for review after you have received the final document. You can do this yourself after logging into your personal account or by contacting our support.

Prompt Delivery and 100% Money-Back-Guarantee

All papers are always delivered on time. In case we need more time to master your paper, we may contact you regarding the deadline extension. In case you cannot provide us with more time, a 100% refund is guaranteed.

Original & Confidential

We use several writing tools checks to ensure that all documents you receive are free from plagiarism. Our editors carefully review all quotations in the text. We also promise maximum confidentiality in all of our services.

24/7 Customer Support

Our support agents are available 24 hours a day 7 days a week and committed to providing you with the best customer experience. Get in touch whenever you need any assistance.

Try it now!

Calculate the price of your order

Total price:
$0.00

How it works?

Follow these simple steps to get your paper done

Place your order

Fill in the order form and provide all details of your assignment.

Proceed with the payment

Choose the payment system that suits you most.

Receive the final file

Once your paper is ready, we will email it to you.

Our Services

No need to work on your paper at night. Sleep tight, we will cover your back. We offer all kinds of writing services.

Essays

Essay Writing Service

No matter what kind of academic paper you need and how urgent you need it, you are welcome to choose your academic level and the type of your paper at an affordable price. We take care of all your paper needs and give a 24/7 customer care support system.

Admissions

Admission Essays & Business Writing Help

An admission essay is an essay or other written statement by a candidate, often a potential student enrolling in a college, university, or graduate school. You can be rest assurred that through our service we will write the best admission essay for you.

Reviews

Editing Support

Our academic writers and editors make the necessary changes to your paper so that it is polished. We also format your document by correctly quoting the sources and creating reference lists in the formats APA, Harvard, MLA, Chicago / Turabian.

Reviews

Revision Support

If you think your paper could be improved, you can request a review. In this case, your paper will be checked by the writer or assigned to an editor. You can use this option as many times as you see fit. This is free because we want you to be completely satisfied with the service offered.