A Corporate Restructuring That Triggered a CRA Reassessment

Описание: Selling investment property through a corporation can attract close attention from the Canada Revenue Agency, especially when ownership or control changes before the sale.

In this video, I walk through a real Tax Court of Canada case, Lark Investments Inc. v. The King (2024 TCC 30). The Court reviewed a situation where a holding company changed its control structure shortly before selling investment property and paying a large capital dividend. The CRA applied the General Anti-Avoidance Rule and reassessed the transaction based on how the structure interacted with Canada’s corporate tax system.

The Court focused on whether the CRA clearly explained its reasoning and how the facts and timing supported its position. While the final tax outcome is still to be decided, the case highlights how corporate restructurings, investment property sales, and documentation all play a role in CRA reviews.

This video explains the case in simple terms and shares practical planning lessons for business owners who hold investment assets inside corporations.

At Cloudiverse CPAs in Burnaby, we help business owners plan investment property sales, corporate restructurings, and tax strategies with a clear focus on managing CRA risk before major transactions take place.

Case link (publicly available decision):
https://decision.tcc-cci.gc.ca/tcc-cc...

If you are planning a property sale, corporate reorganization, or dividend, reach out to discuss your situation.
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