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Tax Court Shuts Down Foreign Continuance Loophole: CRA can Tax a Canadian-Controlled Private Corporation (CCPC): Lessons from Somerset Limited v The King, 2026 TCC 123

Written by

David Rotfleisch

Last updated on August 14, 2026

Contents

Overview – Why the Offshore Continuance Failed

In Somerset Limited v The King, 2026 TCC 123, the Tax Court of Canada considered whether a Canadian private corporation could reduce the tax on a major property sale by continuing from British Columbia into the British Virgin Islands (BVI). Somerset Limited remained resident in Canada, but it argued that the change in its jurisdiction of incorporation meant that it was no longer a Canadian-controlled private corporation (CCPC).

That distinction mattered because CCPCs are subject to special rules for investment income. Section 123.3 of the Income Tax Act imposes an additional refundable tax on a CCPC’s investment income, while section 123.4 limits access to the general corporate rate reduction for that income. Somerset’s position was that the BVI continuance removed it from those rules before it realized a substantial capital gain on the sale of two Vancouver apartment buildings.

The Tax Court rejected the argument. Justice MacPhee held that Somerset remained a “Canadian corporation” under subsection 89(1) and therefore remained a CCPC under subsection 125(7). Although subsection 250(5.1) treated Somerset as having been incorporated in the BVI, the same rule brought the corporation within another part of the Canadian-corporation definition. The continuance changed the route by which Somerset qualified as a Canadian corporation, but it did not end that status.

The Court also concluded that the general anti-avoidance rule (GAAR) in section 245 would have denied the expected tax benefits even if Somerset’s technical interpretation had succeeded. In Canada v DAC Investment Holdings Inc, 2026 FCA 35, the Federal Court of Appeal reversed the 2024 Tax Court decision and held that the BVI continuance was a formal step with no meaningful change in economic or commercial reality. It also held that subsection 245(2) could not alter the normal reassessment period. Although the planning was comparable, DAC involved an Ontario corporation selling subsidiary shares and realizing an approximately $2.36 million gain. DAC sought leave to appeal to the Supreme Court of Canada on April 21, 2026; as of August 5, 2026, the application remained pending.

The decision demonstrates why corporate continuance planning should be reviewed before a sale agreement, reorganization or dividend becomes legally binding.

Find a tax lawyer who can assess whether the proposed tax treatment is supported by the ordinary statutory provisions, whether GAAR creates additional exposure and how CRA may approach the transaction during a CRA tax audit or reassessment.

“Somerset shows that changing a corporation’s legal home is not the same as changing its Canadian tax position. Business owners and their advisors must examine how the continuance interacts with the corporation’s residence, status, tax accounts and intended distributions before assuming that the transaction will produce tax savings.”

  • David J. Rotfleisch, Certified Specialist in Taxation Law and experienced Canadian Tax Lawyer.

Background – The British Virgin Islands Continuance and the Property Sale

Somerset was incorporated in British Columbia in 1943. It held rental real estate and publicly traded shares, remained resident in Canada, and was owned by four Canadian-resident shareholders. Before the disputed transactions, it was unquestionably a CCPC.

  • In October 2018, Somerset agreed to sell two Vancouver apartment buildings to Starlight Acquisitions Ltd. for an adjusted purchase price of approximately $34 million.
  • The sale closed on December 17, 2018.
  • Because Somerset’s relevant taxation year ran from December 16, 2018 to December 15, 2019, the resulting approximately $32 million capital gain—and approximately $16 million taxable capital gain—was reported in its 2019 taxation year.
  • CRA later reassessed that year, together with Somerset’s 2020 and 2021 taxation years.

Before closing, Somerset continued from British Columbia into the BVI. Continuance is a statutory mechanism that allows a corporation governed by the corporate law of one jurisdiction to become subject to the laws of a different jurisdiction, with a crucial feature being that the corporation is treated as if it were incorporated in the new jurisdiction. The agreed facts expressly stated that its primary purpose in doing so was to avoid the additional tax under section 123.3. Somerset did not, however, move its central management and control or otherwise cease Canadian residence. It conceded that it remained resident in Canada after the continuance.

Somerset’s primary purpose in undertaking the continuance was to avoid the section 123.3 tax for which it was later reassessed. Section 123.3 of the Income Tax Act imposes an additional tax equal to 10 2/3% of the lesser of the corporation’s aggregate investment income for the year and the amount by which its taxable income for the year exceeds certain deductions. This provision applies only to corporations that are Canadian-controlled private corporations throughout the taxation year. The term “aggregate investment income” is defined in subsection 129(4) and includes the eligible portion of taxable capital gains and income from property sources.

The tax differential Somerset sought to exploit was significant. At the federal level, a private corporation that is not a CCPC is taxed on investment income at 15% after the general rate reduction, while a CCPC is taxed on aggregate investment income at 28% plus the additional refundable tax under section 123.3, which was increased to 10 2/3% after 2015, resulting in a CCPC paying tax at 38.66% on aggregate investment for Somerset’s 2019 taxation year. Provincial corporate tax applies in addition to these federal rates. By continuing to the BVI, Somerset believed it would cease to be a CCPC and would no longer be subject to section 123.3, thereby reducing its effective federal tax rate on the substantial capital gain from the building sale by approximately 23.66 percentage points.

That comparison overstates the permanent benefit, because a substantial part of the tax paid by a CCPC on investment income is refundable through the refundable corporate dividend tax on hand mechanism when taxable dividends are paid to shareholders. The advantage that the CCPC investment-income rules are designed to remove is therefore largely one of deferral, which is also why the Federal Court of Appeal in DAC treated the planning as defeating an anti-deferral policy.

Somerset later reorganized its shareholders’ interests through holding companies and paid substantial dividends, including approximately $6.37 million designated as eligible dividends in 2019 and $2 million in 2020.

Somerset filed its returns without paying section 123.3 tax and claimed the section 123.4 rate reduction. CRA reassessed its 2019, 2020 and 2021 taxation years, imposed the additional tax, denied the rate reduction and treated the eligible-dividend designations as excessive. Somerset elected under subsection 185.1(2), with the concurrence of the shareholders who received the dividends, to treat the excessive portions as separate non-eligible dividends, avoiding Part III.1 tax on those designations.

Why Somerset Still Counted as a Canadian Corporation

The central issue was whether Somerset remained a “Canadian corporation” after the BVI continuance. Under subsection 125(7), a private corporation generally must be a Canadian corporation before it can qualify as CCPC. Because Somerset remained privately owned and controlled by Canadian residents, its status turned mainly on the Canadian-corporation definition in subsection 89(1).

Subsection 89(1) provides two routes into that definition. Paragraph 89(1)(a) covers a corporation that was incorporated in Canada. Paragraph 89(1)(b) covers a corporation that was incorporated outside Canada but has remained resident in Canada continuously throughout the period beginning on June 18, 1971.

Before the continuance, Somerset clearly qualified under paragraph 89(1)(a) because it had been incorporated in British Columbia. Somerset argued that subsection 250(5.1) changed that result. That provision says, in simplified terms, that when a corporation continues into another jurisdiction, it is treated for most purposes of the Income Tax Act as having been incorporated in the new jurisdiction (the British Virgin Islands) and not in the former jurisdiction (British Columbia, Canada).

In Somerset’s case, paragraph 250(5.1)(a) deemed the corporation to have been incorporated in the BVI rather than in British Columbia. That deeming rule addresses where the corporation is treated as having been incorporated; it does not disturb the corporation’s actual history of Canadian residence, and it is that residence history that becomes decisive under paragraph 89(1)(b).

Somerset therefore argued that it should be treated as having been incorporated in the BVI rather than Canada. On that narrow point, the Court agreed. After the continuance, Somerset could no longer rely on paragraph 89(1)(a), because the tax rules treated it as foreign-incorporated.

The difficulty for Somerset was that the analysis did not stop there. Once the corporation was treated as having been incorporated outside Canada, paragraph 89(1)(b) became relevant. Somerset had been resident in Canada continuously since well before June 18, 1971. It therefore met the residence requirement in that paragraph.

The Tax Court concluded that the continuance moved Somerset from one route into the Canadian-corporation definition to the other. Before the continuance, it qualified because it was incorporated in Canada. After the continuance, it qualified because it was treated as foreign-incorporated while continuing to satisfy the long-standing Canadian residence requirement.

Specifically, the Court stated that paragraphs 89(1)(a) and (b) address different groups of corporations. The first generally applies to corporations incorporated in Canada. The second preserves Canadian-corporation status for certain foreign-incorporated corporations with continuous Canadian residence dating back to June 18, 1971.

The tax consequences proved unexpected for Somerset. Because it had been resident in Canada without interruption since long before June 18, 1971, it was captured by paragraph 89(1)(b) of the Canadian-corporation definition once it was treated as foreign-incorporated, meaning it did not cease to be a CCPC after the continuance but simply shifted from being a Canadian corporation under paragraph 89(1)(a) to one under paragraph 89(1)(b). This illustrates how the continuance deeming provisions interact with other Income Tax Act definitions to determine a corporation’s tax status and obligations.

The broader practical point is straightforward. A tax rule that treats a fact as true must be followed through to all of the consequences that Parliament attached to that fact. Somerset could not rely on subsection 250(5.1) to say that it was no longer incorporated in Canada while ignoring that the same foreign-incorporation treatment allowed paragraph 89(1)(b) to apply.

“The corporation focused on the part of the continuance rule that appeared to remove it from Canadian incorporation. The Court looked at the entire definition and found that the same rule preserved Somerset’s Canadian-corporation status in a different way. Tax planning must account for both the favourable and unfavourable consequences of a statutory rule.”

– David J. Rotfleisch.

Because Somerset remained a Canadian corporation, it remained a CCPC. The additional tax under section 123.3 continued to apply to its investment income, and that income remained excluded from the general corporate rate reduction under section 123.4.

Why GAAR Still Put the Expected Tax Savings at Risk

The Court’s interpretation of the ordinary tax rules was enough to dismiss Somerset’s appeal. Moreover, the court found alternatively that if Somerset had ceased to be a CCPC, the application of the General Anti-Avoidance Rule (GAAR) in section 245 would have denied the tax benefits. The court was bound by the Federal Court of Appeal’s reasoning and application of GAAR in Canada v DAC Investment Holdings Inc, 2026 FCA 35 (DAC), and stated that even if Somerset was found not to be a Canadian corporation as a result of the continuance, GAAR would still apply. This part of the decision was important because it showed that the planning faced serious risk even if Somerset had succeeded on the wording of the Canadian-corporation definition.

GAAR is found in section 245 of the Income Tax Act. In broad terms, it allows CRA and the courts to deny a tax benefit where a transaction or series technically fits within the legislation but misuses a provision or defeats the purpose of the relevant rules. GAAR does not make ordinary tax planning improper. It applies where the way the provisions are used is inconsistent with what Parliament intended them to accomplish.

Section 245 has since been amended, and the amendments matter to any taxpayer considering similar planning today. The avoidance-transaction test now requires only that one of the main purposes of a transaction be obtaining a tax benefit, rather than a primary purpose. Subsection 245(4.1) directs that a transaction significantly lacking economic substance tends to indicate abusive tax avoidance, which addresses directly the kind of formal jurisdictional change at issue in Somerset and DAC. Subsection 245(5.1) imposes a penalty of 25% of the denied tax benefit, subject to a defence where the transaction was disclosed to CRA or where the taxpayer relied in good faith on established case law or administrative practice. The normal reassessment period is also extended by three years for GAAR assessments.

Somerset and DAC were both decided under the earlier version of section 245, so neither decision applies the economic-substance rule or the penalty. A corporation that attempted comparable planning after the amendments would face a materially worse risk profile than the taxpayers in those cases, and the availability of the disclosure defence would become a central planning consideration rather than an afterthought.

In Canada Trustco Mortgage Co v Canada, 2005 SCC 54, the Supreme Court of Canada established the foundational three-stage framework for applying the general anti-avoidance rule under section 245 of the Income Tax Act. Under the version of section 245 considered by the Court, the analysis proceeded through three distinct questions:

  1. Tax benefit: Did the transaction, or a series that included the transaction, produce a reduction, avoidance, or deferral of tax?
  2. Avoidance transaction: Was the transaction undertaken or arranged primarily to obtain that tax benefit rather than for a bona fide non-tax purpose?
  3. Misuse or abuse: Did the resulting tax benefit frustrate the object, spirit, or purpose of the relevant statutory provisions, considered in their broader legislative context?

The Court’s allocation of the evidentiary burden is equally important. The taxpayer must refute the CRA’s assumptions concerning the existence of a tax benefit and the characterization of the transaction as an avoidance transaction. The CRA, however, bears the practical burden of demonstrating abusive tax avoidance. Where abuse has not been clearly established, the benefit of the doubt must go to the taxpayer.

This allocation materially affects how an experienced tax litigation lawyer approaches a GAAR dispute. Evidence of genuine commercial, family, or other non-tax purposes remains important, but the central battleground is frequently the misuse-or-abuse analysis. A persuasive GAAR defence must therefore explain not merely why the transaction complied with the statutory text, but why the tax result remained consistent with the object, spirit, and purpose of the provisions Parliament enacted.

Somerset accepted that the transactions produced a tax benefit and that the BVI continuance and related steps were avoidance transactions for GAAR purposes. The remaining question was whether the planning was abusive.

The Federal Court of Appeal’s decision in DAC largely determined the answer, because the circumstances were closely comparable. A Canadian-resident CCPC continued into the BVI before realizing a major capital gain and argued that it had escaped the additional tax under section 123.3 and gained access to the section 123.4 rate reduction.

The Federal Court of Appeal in DAC held that the planning frustrated the purpose of the CCPC investment-income rules. Those rules are designed to limit the tax-deferral advantage that could arise when individuals earn passive investment income through a private corporation rather than earning it directly. A corporation should not be able to avoid that regime merely by changing its corporate-law jurisdiction while remaining resident, controlled and economically active in Canada in the same manner.

The Federal Court of Appeal released DAC on February 20, 2026, reversing a Tax Court decision that had found the same planning non-abusive. It held that the Tax Court had stated Parliament’s intent too broadly, and that the continuance was a formal step producing no change in the corporation’s economic or commercial reality. The Court also rejected the taxpayer’s argument on the GAAR remedy, holding that subsection 245(2) permits only the adjustments necessary to deny the tax benefit obtained and does not extend to altering the normal reassessment period. The facts in DAC were not identical to those in Somerset: the taxpayer there was incorporated in Ontario, sold shares of a subsidiary rather than real estate, and realized a much smaller gain. The status of any application for leave to appeal to the Supreme Court of Canada should be confirmed as at the date of posting.

The same reasoning applied to Somerset. Its BVI continuance changed the statute governing the corporation, but it did not change where the corporation was managed, where it was resident, who controlled it, what assets it owned or the economic substance of its activities. The agreed facts also stated that the primary purpose of the continuance was to avoid section 123.3. The Court therefore concluded that, had Somerset ceased to be a CCPC under the ordinary rules, GAAR would have restored the intended tax result. The section 123.3 tax would still have applied, and the section 123.4 rate reduction would still have been denied.

For business owners, the message is not that an offshore continuance is automatically improper. A corporation may have genuine commercial, regulatory or operational reasons to continue into another jurisdiction. The risk arises when the corporation remains economically and factually connected to Canada, while the continuance is used mainly to obtain a tax result that is inconsistent with the purpose of the Canadian tax rules.

Do the Substantive CCPC Rules End This Planning?

Somerset and DAC both concern taxation years that predate the substantive CCPC rules. Those rules, added to subsection 248(1) of the Income Tax Act by Bill C-59, apply to taxation years ending on or after April 7, 2022. In general terms, a private corporation resident in Canada is a substantive CCPC where it is controlled in fact by one or more Canadian-resident individuals, or where it would be a CCPC but for the fact that a non-resident or public corporation has a right to acquire its shares. A substantive CCPC is treated as a CCPC for the purposes of the additional refundable tax under section 123.3 and the aggregate investment income rules.

The practical consequence is significant. A corporation that continues into the British Virgin Islands today while its central management and control, its shareholders and its business all remain in Canada will ordinarily be a substantive CCPC, and the section 123.3 tax will apply to its aggregate investment income without CRA needing to invoke GAAR at all. The planning that Somerset and DAC attempted has been closed prospectively by the ordinary provisions, and the two decisions are best understood as resolving legacy years rather than as guidance on what is available now.

That does not mean every cross-border corporate step is foreclosed. A genuine migration in which central management and control actually moves outside Canada can change the corporation’s tax residence, but it engages a different and more demanding set of rules, including the deemed disposition on emigration under subsection 128.1(4), the additional tax under subsection 219.1(1), the corporate residence tie-breaker in any applicable tax treaty and the loss of Canadian tax accounts. Those consequences are frequently more expensive than the CCPC tax the corporation was trying to avoid, and they should be quantified before any step is taken.

Implications for Canadian Private Corporations After Somerset

A corporate continuance does not automatically change tax residence or end CCPC status. The corporation may change the law under which it exists while remaining fully taxable in Canada. Before proceeding, owners should review residence, control, management, the place of incorporation and every tax rule that depends on corporate status.

The effects can extend beyond the tax rate on a sale. A wrong status determination may affect refundable tax balances, eligible dividends, the small business deduction and the shareholder-level tax payable when corporate funds are distributed.

The case also shows the importance of the factual record. Board minutes, professional advice, tax calculations and evidence of genuine commercial objectives may become central during a CRA tax audit or tax appeal. Where the documents show that the main purpose was to avoid a specific tax rule and little else changed, the GAAR risk will be difficult to overcome.

Strategic Takeaways for Foreign Continuance Planning and CRA Tax Reassessments

The main planning lesson from Somerset is that a foreign continuance should never be treated as a stand-alone corporate step. Before proceeding, advisers should map how the continuance affects the corporation’s residence, Canadian-corporation status, CCPC or substantive-CCPC status, refundable tax accounts, GRIP, capital dividend account, shareholder distributions and any pending sale or reorganization. The analysis should begin with the ordinary statutory provisions. GAAR should then be considered as a separate risk assessment rather than as the only possible basis for a CRA challenge.

Timing is equally important. Where a continuance occurs shortly before a major capital gain, dividend or sale, CRA will likely examine the sequence as one connected series. Board minutes, tax memoranda and commercial records should therefore explain what was expected to change in legal, operational and economic terms. A generic reference to “international flexibility” will carry little weight if management, control, assets and business operations remain unchanged.

If CRA reassesses, the response should address both the technical status issue and any alternative GAAR position. The taxpayer should identify the precise assumptions underlying the CRA tax reassessment, preserve contemporaneous evidence and calculate all secondary consequences, including interest, dividend-account adjustments and shareholder-level tax. Somerset shows that early, integrated advice is generally more effective than attempting to defend a narrow statutory interpretation after the transaction has closed.

Pro Tax Tips: Review Corporate Status Before a Major Realization

Before a private corporation sells appreciated property or completes a major reorganization, its advisors should confirm the corporation’s Canadian residence, jurisdiction of incorporation, CCPC status, investment-income exposure and relevant tax accounts. This review should be completed before the sale agreement becomes binding and before dividends or other distributions are declared.

Owners should also examine what will change in substance. A continuance that changes only the governing corporate statute may not change the corporation’s Canadian tax treatment. The proposed structure should be tested under the ordinary provisions and GAAR, and the projected tax results should include the consequences for the corporation and its shareholders.

If CRA later challenges the planning, preserve board materials, correspondence, valuations, calculations and evidence supporting any non-tax reasons for the transaction. The strength of a tax appeal often depends not only on the legal argument but also on the facts established before and during the transaction.

“Major transactions should be reviewed as one connected plan. The sale, the corporation’s status, its tax accounts and the later distribution of proceeds can all affect one another. Addressing those issues before closing is usually far less costly than defending an unexpected CRA tax reassessment afterward.”

FAQs: Foreign Continuance, CCPC Status and GAAR

Does continuing a Canadian corporation offshore automatically change its Canadian tax residence?

No. A continuance changes the jurisdiction governing the corporation, but it does not necessarily change where the corporation is resident for tax purposes. In Somerset, the corporation continued into the BVI but remained resident in Canada because its management and control did not materially move outside Canada.

Can a corporation remain a CCPC after a foreign continuance?

Yes. CCPC status depends on the complete statutory definitions, not merely the corporation’s new jurisdiction of incorporation. In Somerset, subsection 250(5.1) deemed the corporation to be incorporated in the BVI, but its continuous Canadian residence brought it within paragraph 89(1)(b), preserving its Canadian-corporation and CCPC status.

Will an offshore continuance automatically reduce Canadian corporate tax?

No. The expected tax savings may fail if the corporation remains resident in Canada or continues to satisfy the CCPC rules. In Somerset, the BVI continuance did not eliminate the additional tax under section 123.3 or provide access to the section 123.4 general corporate rate reduction.

Did the Court in Somerset decide that every foreign continuance is abusive?

No. The decision concerns a Canadian-resident corporation that continued offshore specifically to escape the CCPC anti-deferral regime without a corresponding economic or residence change. The tax consequences of a genuine corporate migration depend on the complete facts, applicable treaties and departure-tax rules.

When may GAAR apply to an offshore continuance?

GAAR may apply where a continuance technically produces a tax benefit but frustrates the purpose of the relevant tax provisions. Risk is particularly high where the corporation’s residence, control, management and economic activities remain unchanged. In Somerset, the Court found that GAAR would have denied the tax benefits in any event.

Does having a commercial reason prevent GAAR from applying?

Not necessarily. A genuine commercial purpose may support the taxpayer’s position, but it does not automatically prevent GAAR from applying. CRA and the courts will examine the entire series and its practical effects. In Somerset, the agreed facts stated that the primary purpose of the continuance was avoiding section 123.3 tax.

What should a business owner review before continuing a corporation into another jurisdiction?

The review should include the corporation’s tax residence, ownership and control, management location, CCPC status, investment income, tax accounts, departure-tax exposure and intended distributions to shareholders. The owner should also identify and document any commercial reasons for the continuance and obtain advice before signing transaction documents or completing a related asset sale.

Should a foreign continuance be completed before a major asset sale?

Timing alone does not ensure the desired tax result. A continuance completed shortly before a significant sale may attract CRA scrutiny, especially where little changes apart from the governing corporate law. In Somerset, the BVI continuance occurred before the sale of valuable Vancouver properties and was examined as part of the overall series.

What records should a corporation keep to support a foreign continuance?

The corporation should preserve board minutes, legal and tax advice, financial projections, correspondence and evidence of commercial objectives. Records should explain what was expected to change operationally and economically. In Somerset, the admitted tax purpose and lack of meaningful change to the corporation’s Canadian activities weakened the taxpayer’s position.

What should a corporation do after receiving a CRA tax reassessment?

The corporation should promptly review the tax reassessment, CRA’s assumptions and any tax audit or proposal letters. It should identify all disputed issues, preserve relevant records and calculate the full tax and interest exposure. An experT tax litigation lawyer for CRA disputes can prepare a notice of objection and develop the evidentiary and legal strategy.

Can a foreign continuance trigger a CRA tax audit?

Yes. A foreign continuance, especially one completed shortly before a major asset sale or dividend, may attract CRA tax audit scrutiny. CRA may review the corporation’s residence, CCPC status, commercial purpose, tax accounts and related transactions. In Somerset, the continuance formed part of a broader series examined by CRA.

What are the substantive CCPC rules and do they end continuance planning?

The substantive CCPC rules in subsection 248(1) of the Income Tax Act apply to taxation years ending on or after April 7, 2022. They treat a private corporation resident in Canada that is controlled in fact by Canadian-resident individuals as a CCPC for the additional refundable tax under section 123.3 and the aggregate investment income rules, even where it is no longer a CCPC under the ordinary definition. A continuance that leaves management, control and shareholders in Canada will therefore usually not achieve the intended result today, without CRA needing to rely on GAAR.

Yes. Subsection 245(5.1) imposes a penalty of 25% of the denied tax benefit where GAAR applies. The penalty does not apply where the transaction was disclosed to CRA, or where the taxpayer establishes that it acted in reliance on established case law or CRA administrative practice at the time. The normal reassessment period is also extended by three years for GAAR assessments, which lengthens the period during which CRA may act.

Does GAAR now consider economic substance?

Yes. Subsection 245(4.1) provides that a transaction that significantly lacks economic substance tends to indicate abusive tax avoidance. Neither Somerset nor DAC was decided under that provision, but both concerned transactions that changed the corporation’s legal form without changing its economic position, which is exactly the pattern the amendment targets.

Is a foreign continuance the same as moving a corporation’s tax residence out of Canada?

No. A continuance changes the corporate law that governs the corporation. Tax residence depends on where central management and control is exercised, and on any applicable tax treaty tie-breaker. An actual emigration engages the deemed disposition under subsection 128.1(4), the additional tax under subsection 219.1(1) and the loss of Canadian tax accounts, so the cost of a genuine residence change is frequently higher than the tax the corporation was seeking to avoid.

DISCLAIMER: This article provides broad information. It is only accurate as of the posting date. It has not been updated and may be out-of-date. It does not give legal advice and should not be relied on as tax advice. Every tax scenario is unique to its circumstances and will differ from the instances described in the article. If you have specific legal questions, you should seek the advice of a Canadian tax lawyer.