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Published: July 2, 2021

Last Updated: July 8, 2021

Canadian tax expert David Rotfleish was recently featured in an artcle on In this article, he tackles the negative implications of Section 84.1 of the Income Tax Act, which is also known as Surplus/Dividend Triping.

“Although many surplus-stripping transactions rely on the lifetime capital gains exemption, section 84.1 tax trap doesn’t solely target transactions involving the lifetime capital gains exemption. It potentially applies anytime an individual transfers shares to a holding corporation. And when it applies, section 84.1 can lead to severe tax costs. Yet the section 84.1 tax trap often goes unnoticed by tax advisers when structuring a share-sale transaction or a corporate reorganization.”

Read the full article here.


"This article provides information of a general nature only. It is only current at the posting date. It is not updated and it may no longer be current. It does not provide legal advice nor can it or should it be relied upon. All tax situations are specific to their facts and will differ from the situations in the articles. If you have specific legal questions you should consult a lawyer."

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