• the estate freeze - don't forget about the value accumulated in a family trust when estate planning. Otherwise, you may find yourself making elaborate instructions in your Will without considering that your personal assets are worth only a fraction of your business and investment interests.

• personally held assets - you could benefit from transfering buildings and other assets into a corporation or partnership, so that the exposure on the deemed disposition would be treated as a capital gain, rather than be fully taxable.

• Pre-Mortem Redemptions - if a corporation is generating refundable tax, it may be advantageous to systematically redeem freeze shares (as the personal tax resulting from deemed dividends on redemption would largely be tax-paid).

• family law considerations - keep in mind that if an estate freeze was effected prior to the marriage of a beneficiary, it is not clear that a distribution from the trust after the marriage would be protected from a family law claim (if the marriage ended), which could mean a fight over the post-marriage appreciation.
  Until tomorrow,
  
  
  

Natalia R. Angelini