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$44 for 44% of the shares: flawless fair market value, or a taxable gift?
Picture the scene. A business owner reorganizes their company. In the new structure, a family member — say their spouse — subscribes for 44% of the participating shares for the grand sum of $44. Forty-four dollars. For 44% of a company that may be worth several hundred thousand dollars. At first glance, it smells like a suspicious bargain. And the Canada Revenue Agency's first question would be: is that really fair market value (FMV)? The perfect-stranger test Here's a simple
danyturgeon
Jul 33 min read
Some Tax Decisions Cannot Be Undone
Some tax decisions can be adjusted. Others can be corrected. But some, once implemented, cannot be undone. Quality tax planning requires understanding what is being locked in before it is too late.
danyturgeon
Apr 142 min read
Risk Is the Real Cost of Tax
Tax is the visible cost. Risk is often the real one. Quality tax planning is about making defensible decisions and understanding the trade‑offs when the cost of being wrong is material.
danyturgeon
Mar 312 min read
Why “Saving Tax” Is the Wrong Objective
Most people who come to see me start with the same question: “How can I pay less tax?” It sounds reasonable. It is also the wrong place to start. The objective of good tax planning is not to “save tax.”The objective is to make a defensible decision when the cost of being wrong is material . There is an important difference. Some tax positions reduce tax today but increase risk tomorrow. Others do the opposite. And some decisions cannot be undone once they are implemented. Tha
danyturgeon
Mar 151 min read
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