ESTATE FREEZE (PG. 299-319) Flashcards
ESTATE FREEZE
To cause some or all of the future growth on the assets to accrue to another individual (capping the accrued income tax liability associated with those assets)
FREEZOR
Person who owns significant assets that are growing in value
RECIPIENT
Person(s) who will benefit from the freeze by gaining entitlement to the future growth component
SECTION 85 ELECTION
Freezor transfers the shares of the corporation (opco) to another corporation (holdco), taking back fixed-value retractable redeemable preferred shares of the new corporation (holdco) in exchange
SECTION 86 REORGANIZATION OF CAPITAL
Freezor excahnges common shares of the corporation (opco) for fixed-value retractable redeemable preferred shares of the corporation (opco)
STOCK DIVIDEND FREEZE
The freezing of a corporation
PARTIAL FREEZE
Freezing the value of the current asset and subscribing to some of the growth shares along with the other intended participants
SYSTEMATIC REDEMPTION
When a freezor decides to manage his/her income by requesting that dividends be paid on the preferred shares, under which some of the freezor’s fixed-value retractable redeemable preferred shares are redeemed annually.