Victor & Gold - Edward Victor, CMC, FCA

Notepad:
Edward Victor, CMC, FCA

Dear Clients:

date: 01/11/06

We have been involved with an intricate tax case, which recently resulted in an appeal court ruling that we believe will assist Canadian taxpayers design and implement tax plans with greater clarity.

A company can generally transfer capital to a connected corporation tax-free, as long as the transfer is part of its “safe income”, which corresponds roughly to “retained earnings for tax purposes”. The Income Tax Act does not provide specific guidance at to how “safe income” is determined.

This case went to court several years ago (Kruco 2003 DTC 5506) and, unhappy with the outcome, the Canada Revenue Agency appealed the court decision. Notably, the recent ruling issued by the Federal Court of Appeal specifically disagrees with aspects of the Canada Revenue Agency’s computation of “safe income”, and the ruling has now clarified major elements of this computation.

As a result of this important case, there is now a clearer definition of “safe income”, which will add certainty to many corporate reorganizations in the future.

I would be pleased to hear any comments or field any questions that you may have relating to “safe income”.

date: 12/06/06

Victor & Gold is often called upon to advise families on estate planning, primarily to reduce income tax exposure, to equalize inheritances amoung family members, and to avoid litigation wherever possible.

The firm is also called upon to act as an arbitrator to resolve disputes between vendors and purchasers of corporations.

We recently completed a very complex mandate, serving as the binding arbitrator engaged to resolve a dispute between a purchaser and a vendor of a private company.

Please contact me if you wish to find out more about how an arbitrator can settle a dispute without going to court.

date: 02/03/06

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	Contact Edward Victor
	Edward Victor

Partners:

F. Leboff

E. Victor

B. Shiller

J. Levy

S. Plante

K. Shemie

Edward Victor, CMC, FCA
Senior Tax Partner

Areas of Professional Expertise

Advising small and medium sized private corporations
Corporate and personal income tax
Estate planning
Arbitration
Family business planning
Acquisitions and mergers

Education & Designations

Bachelor of Commerce (McGill University)
Fellow Chartered Accountant (FCA) (Québec)
Chartered Accountant designation (Québec, Ontario)
Certified Management Consultant (Institute of Management Consultants)
STEP designation (Society of Trust and Estate Practitioners, England)