Specialty II
Corporate reorganization
Strategic restructurings: section 85 rollovers, estate freezes, family-trust implementation, holding companies. Every transformation planned over 3 to 5 years.
For whom
Typical engagement profiles.
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01
Entrepreneurs planning to sell their business in 3 to 5 years who want to crystallize the lifetime capital-gains exemption today.
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02
Owner families considering an intergenerational transfer — Bill C-208 — to the next generation.
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03
Operating companies generating excess liquidity that would benefit from a holding structure to protect assets and optimize taxation.
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04
Spouses or business partners in shareholder reorganization, separation, or share buy-out.
What's included
Six concrete deliverables.
- Section 85(1) rollovers with CRA + Revenu Québec
- Estate freezes and value crystallization
- Discretionary family-trust setup
- Holding structures and corporate tiers
- Sale-readiness (purification, LCGE multiplication)
- Intergenerational transfers compliant with Bill C-208
Our process
Four steps. No surprises.
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01
Diagnostic
Full wealth-and-business diagnostic — assets, liabilities, shareholding, 5-year objectives, current and projected taxation.
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02
Modelling
Design of the target structure — holding, trust, corporate tiers, crystallized value — with tax projections.
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03
Execution
Technical implementation: section 85(1) rollovers, estate freezes, trust setup, articles amendments, registers.
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04
Follow-up
Special filings, CRA + Revenu Québec post-restructuring compliance, year-over-year adjustments.
Sample engagements
Recent files, anonymized.
Details modified to respect professional secrecy. Structures and techniques are representative of real engagements.
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CASE 01
Estate freeze + family trust
56-year-old shareholder, 100% of an operating company worth $8M. Engagement: estate freeze into a family trust for the benefit of three children, LCGE crystallization, holding company to lock in the current value.
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CASE 02
Share buy-out between spouses
Two co-owner spouses separating. Engagement: section 85(1) rollover to transfer shares from one to the other with no immediate tax impact, register updates, audit file for the bank financing the buy-out.
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CASE 03
LCGE multiplication ahead of sale
Business group targeting a sale in 4 years. Engagement: purification of the operating company, setup of discretionary trusts for adult children, annual follow-up through to the transaction.