David Rotfleisch, a tax lawyer with Rotfleisch & Samulovitch P.C. in Toronto, explained why executives and employees should treat share transfers as income rather than capital gains, which is the norm.
“Had the approach worked, there would have been a tax-free crystallization for the controlling shareholder and a tax-free receipt of proceeds for the arm’s length employees,” says Rotfleisch. “A nice win for everyone but the Canada Revenue Agency,” he added
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