Tax Hyperion, Vol. 18, Issue 2, March-April 2021
Intercorporate Shareholdings and 110.6(15)(b)—Are You Offside?
When setting up a corporate structure, a client’s ability to access their Lifetime Capital Gains Exemption is front of mind for any practitioner. However, when business planning is undertaken, with no foreseeable potential sale of the active business in sight, sometimes, falling offside of the Qualified Small Business Corporation Share (“QSBCS”) definition can, unintentionally, occur. This article explores the implications of paragraph 110.6(15)(b) in the Income Tax Act and serves as a reminder that a corporate structure may become, unintentionally, offside in regards to the QSBCS definition.
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