Victor & Gold - Edward Victor, CMC, FCA

Bloc Note:
Edward Victor, CMC, FCA

Cher 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

The 2010 Winter Olympics in Vancouver present a unique opportunity for corporations to promote and develop their brands.

Consider promoting your company at this international event.


	Contacter Edward Victor
	Edward Victor

Partners:

F. Leboff

E. Victor

B. Shiller

J. Levy

S. Plante

K. Shemie

Edward Victor, CMC, FCA
Associé principal en fiscalité

Sphères d'expertise professionnelle

Conseil auprès de sociétés fermées de taille petite et moyenne
Impôts sur le revenu des sociétés et des particuliers
Planification successorale
Arbitrage
Planification d'entreprises familiales
Acquisitions et fusions

Titres universitaires et professionnels

Baccalauréat en commerce (Université McGill)
Fellow de l'Ordre des comptables agréés (FCA) du Québec
Titres de comptable agréé (Québec, Ontario)
Conseiller en management (Ordre des administrateurs agréés du Québec)