Tax efficient reorganizations to:

• facilitate a division of the business among shareholders, including
  divisive (“butterfly”) reorganizations
• maintain access to the capital gains exemption
• provide access to tax losses in another entity
• preserve family wealth and minimize tax on the death of a shareholder, including estate freeze transactions
• facilitate a shareholder buy-out
• facilitate a marital settlement
• maintain status as a “Canadian-controlled private corporation”
• provide asset protection

Advising on the tax aspects of acquiring a business, including:

• analysis of the implications of an asset versus a share acquisition
• structuring to allow the use of corporate funds to finance the acquisition
• structuring to allow the future deduction of interest on the acquisition debt
• analysis of the implications to the vendor, to facilitate buyer negotiation
• structuring to minimize current tax for the post-acquisition business
• structuring to minimize future tax on a resale of the business

Planning a tax efficient sale of the business, management buy-out or transition to the next generation, including:

• analysis of the implications of an asset versus a share sale
• structuring to access capital gains exemption
• structuring to access “safe income” and the resulting tax deferral
• analysis of the implications of non-competition arrangements
• analysis of the implications to the buyer, to facilitate vendor negotiation