Corporate Tax - Investment Holding Companies

Overview:

The legislation relating to the taxation of investment holding corporations has undergone a number of significant changes over the past several years. This course will review these and other changes using several examples and case studies, as well as examine the issues faced by many clients: Should I maintain or wind up my investment corporation?

Using these examples, this course will provide detailed coverage of the significant changes to the rules governing taxation of investment holding corporations and their impact, including a review of the passive income rules (which can impact the availability of the small business deduction of any associated corporations), the course will provide a high-level overview of the change in the RDTOH rules resulting in two pots of refundable tax, and the general increase in the tax rate for corporate investment income. Planning considerations will also be addressed, including the advantages that may still be available by using an investment holding corporation, the impact of holding private company shares at death and the implications for winding up or maintaining an existing investment holding corporation.

Course Content:

In this course, you will gain knowledge about the following topics:

• Advantages of an investment holding corporation – when to implement
• Integration, tax rates, and related issues
• Income splitting and estate freezes – possible with an investment holding corporation?
• The passive income rules
• High level overview of RDTOH – eligible and non-eligible pools and dividends
• Existing investment holding corporations – wind up or retain?
• Post-mortem planning – an overview of the issues that must be considered for any private company owner on death

Learning Objectives:

Upon completing this course, you should be able to:

• Apply the passive income rules to client situations
• Consider planning alternatives for the passive income rules
• Determine when to use the eligible and non-eligible RDTOH balances
• Analyze the implications for winding up or maintaining an investment holding corporation
• Know when to use an investment holding corporation in the new tax landscape

Who Will Benefit: 

This course is intended for practitioners with private company clients who have accumulated, or expect to accumulate over time, significant corporate-owned non-operating (i.e. passive investment) assets. This course is also useful for sole-practitioners and internal accountants of private companies, including those who work for or within a family office.