How constructive ownership rules for CFCs impact planning and tips for practitioners to limit their reach.
Traps for clients and tips for advisors.
Key considerations for investors.
Cross-border planning challenges for affluent immigrants with global assets.
Timing considerations for late allocations of GST tax exemption before 2026.
Practitioners can use a variety of strategies to shift value.
Administrative and tax issues, along with opportunities.
Craft plans to avoid application of the step transaction doctrine before the exemption potentially gets reduced.
