1. ADVANCED TAX PLANNING STRATEGIES

2. TRUSTS AND CORPORATE STRUCTURE CORPORATE SITUATIONS

3. STRUCTURE 1%99% 100% OPCO HOLD CO FAMILY TRUST WITH ALL FAMILY MEMBERS AS BENEFICIARIES

4. ADVANTAGES *INCOME SPLITTING -SPOUSE/CHILDREN OVER 18/PARENTS/CHILDREN UNDER 18? *MULTIPLICATION OF CGE -SALE OR DEATH *ASSET PROTECTION -HARD/OP ASSETS -CASH: IMMEDIATE AND ONGOING -LIFE INSURANCE PROCEEDS -REDUCTION IN PROBATE AND PROFESSIONAL FEES WITHOUT LOSS OF CONTROL *BUSINESS OWNERS RETIREMENT PLAN -UL OVERFUNDED/LEVERAGE *CONTROL OF DISPOSITION OF SHARES FOR TAX PURPOSES ON DEATH *SUCCESSION PLANNING -TAX/CONTROL/PROTECTION

5. - OPCO (0) HOLD CO $$$ UL FAMILY TRUST DIVIDEND INCOME SPLIT $35,000.00/YR CGE MULITPLIED ($750,000.00 X ?)

6. SALE OF BUSINESS DAVE FAMILY – Wife, two kids (ages 19 & 14) CCPC - $2,500,001.00 DAVEDAVE/WIFE/CHILD19/CHILD14 FMV$2,500,001.00 ACB$1.00 CG$2,500,000.00 CGE$750,000.00 3,000,000.00 (750,000.00 X 4) NET$1,750,000.00$0.00 TAXABLE PORTION$875,000.00$0.00 TAX (40%)$350,000.00$0.00 DIFFERENCE$350,000.00

7. EXAMPLE – INCOME SPLITTING DAVE – FAMILY – Wife, two kids (ages 19 & 14) - CCPC – annual income (personal) $200,000.00 DaveDave/Wife/19 year old INCOMEDave $200,000.00 Dave $130,000. 00 $35,000. 00 Dividend $35,000.00 Dividend TAX RATE39.5% 0% TAX PAYABLE $79,000.00$51,350.0 0 00 NET$121,000.00$78,650.0 0 $35,000. 00 TOTAL HOUSEHOLD INCOME $121,000.00$148,000. 00 DIFFERENCE$27,650.00

8. SITUATION IDENTIFICATION/CLIENT PROFILE CLIENT -HAS A CORPORATION -A FAMILY -WIDE VARIATION IN TAX BRACKETS/LIABILITIES WITHIN FAMILY -CLIENT OR CLIENT CORPORATION HAS A SIGNIFICANT ANNUAL INCOME -CLIENT HAS A LARGE ANNUAL TAX LIABILITY (INCOME/CAPITAL GAINS) -WANTS TO BRING CHILD INTO BUSINESS – POSSIBLE SUCCESSION OR TAKEOVER -IS TALKING ABOUT SELLING BUSINESS -IS INVESTING THROUGH CORPORATION -IS RETIRING, OR TALKING ABOUT IT

9. INTER VIVOS TRUSTS ADVANCED TAX PLANNING

10. TRUST BASICS SETTLORTRUSTEE TRUSTEELegal TRUSTEEOwnership BENEFICIARIES (benefits and use)

11. TRUST PRINCIPLES CONTROL PROTECTION TAX PLANNING/TAX REDUCTION FLEXIBILITY – separate benefit & control - tax deferred roll in/roll out in some cases UNIQUE PROPERTY HOLDING/OWNERSHIP SITUATIONS LIMITATIONS

12. ADVANTAGES/LIMITATIONS *ADVANTAGES*LIMITATIONS -CONTROL-TRANSFER TO TRUST MAY BE - TRUSTEES (OFTEN PARENTS) A DISPOSITION -ASSET PROTECTION- 21 YEAR TRUST RULE - CREDITORS/SPOUSES -TAX REDUCTION -INCOME SPLITTING -CGE MULITPLICATIONS -TAX DEFERRAL -ADVANCE ESTATE PLANNING -SUPPLEMENTS WILL/EPA -AVOIDS PROBATE TAXES -REDUCES PROFESSIONAL FEES

13. KIDDIE TAX - S.120.4 ITA PERSON UNDER 18 YEARS RECEIVING A DIVIDEND FROM CCPC SOLUTIONS: -NOT APPLICABLE TO -SALARIES TO CHILDREN -MONEY LENT AT PRESCRIBED RATE -INVEST IN SHARES WITH DIVIDEND PAYMENTS -INVENT IN INTEREST BEARING TERM DEPOSIT MATURING WHEN CHILD IS 18 -FIXED INCOME TRUST FOR MINORS -DEBT/INTEREST PAYMENTS FROM FAMILY -SECONDARY INCOME

14. TRANSFER OF PROPERTY TO AN INTER VIVOS TRUST EXISTING: X Investment Portfolio (FMV $500.000) REORGANIZATION: X FMVChild 1 and 2 Disposition (1) Y (1)Consideration $500,000 promissory note at 4% TRUST

15. FIXED INCOME TRUST FOR MINORS *S.104(18) FACTORS -RESIDENT -BENEFICIARY YOUNGER THAN 21 YEARS -INCOME RIGHT VESTS (NON-DISCRETIONARY) -ENTITLEMENT OF BENEFICIARY BY 40 ONLY CONDITION *PLANNING -INTEREST FREE LOAN TO CAPITAL BENEFICIARIES -TRUST INTEREST BY SEPARATE DISCRETIONARY TRUSTS

16. Secondary Income $200,000.00capital $20,000.00Growth (attributed to parent) ($8,000.00)Tax $12,000.00In minor’s hands – future growth taxed in minor’s hands at lower rates $200,000.00capital $20,000.00Growth (attributed to parent) ($8,000.00)Tax paid by parent from own funds leave $20,000.00Full in minor’s hands – future growth

17. OWNERSHIP OF FAMILY ASSETS BY AN INTER VIVOS TRUST *COMMON FAMILY ASSET IS COTTAGE -USED BY VARIOUS FAMILY MEMBERS Parents *CONSIDER ACQUIRE COTTAGE BY TRUST -FUNDED BY OPCO DIVIDENDS -PARENTS SHOULD NOT BE BENEFICIARIES OF TRUST -SPECIFIED BENEFICIARY -PRINCIPAL RESIDENCE -S.107(2.01) TRUST TO BENEFICIARY -PRINCIPAL RESIDENCE PLANNING TRUST (1) OPCO

18. TRUST PLANNING FOR NON-SBC SCENARIOS *CONSIDERATION ACQUISITION OF NON-ACTIVE BUSINESS ASSET BY A CORPORATION -NOT A “SBC” *S.74.4(4) TRUST -NO DIVIDEND ENTITLEMENT WHILE A “DESIGNATED PERSON” EXAMPLE: Designated Persons Real Property Financed by mortgage guaranteed by X OPCO TRUST

19. PERSONAL SERVICES TRUST EXISTING: X Employer/Employee REORGANIZATION: SERVICE AGREEMENT X Y Child 1 and 2 1.Employment Agreement with the Trust PUBCO TRUST

20. SITUATION INDENTIFICATION/CLIENT PROFILE  SITUATION IDENTIFICATION -FAMILY SITUATION/FAMILY CONCERN OR ISSUE (BLACK SHEEP/DISABLED CHILD/UNDESIRABLE SPOUSE) -CLIENT HAS SIGNIFICANT ANNUAL INCOME -CLIENT HAS LARGE ANNUAL TAX LIABILITY (INCOME/CAPITAL GAINS) -CLIENT HAS FAMILY BUSINESS -CLIENT HAS BUSINESS WITH NON ACTIVE BUSINESS ASSET (EG: REAL ESTATE) -WIDE VARIATION IN TAX BRACKETS/LIABILITIES -CLIENT HAS UNIQUE PROPERTY HOLDING/OWNERSHIP SITUATION -CLIENT HAS SPOUSE AND CHILDREN BUT IN NOT ENGAGED IN INCOME SPLITTING -CLIENT HAS AN ESTATE TAX ISSUE PENDING

21. 21-YEAR RULE GENERAL *PREVENTS INDEFINITE DEFERRAL OF TAX PROPERTY HELD WITHIN A TRUST -GENERALLY APPLIES TO CAPITAL PROPERTY AND LAND INVENTORY *BE WARY OF IT -S.107(2) PLANNING TOOL *GENERALLY ARISES IN ONE OF TWO SITUATIONS -TESTAMENTARY SPOUSE TRUST -ESTATE FREEZE *IMPORTANT EXCEPTIONS -SPOUSE TRUST -ALTER EGO TRUST -JOINT SPOUSAL/COMMON-LAW PARTNER TRUST -TESTAMENTARY SPOUSE TRUST

22. PLANNING CONSIDERATIONS *PERSONAL TRUST S.107(2) ROLL-OUT -ELIMINATES 21-YEAR RULE ISSUE -BUT NOW THE ASSETS ARE IN THE HANDS OF A BENEFICIARY *ALTERNATIVES TO S.107(2) -S.107(2.001) -S.107(2.002) *ABOVE CAUSE S.107(2.1) TO APPLY -DISTRIBUTION GREATER OF FMV AND COST -CONSIDER IF TRUST HAS TAX SHIELD

23. TRUST SETTLEMENT CONSIDERATIONS *BE VERY CAREFUL -S.75(2) IS ONEROUS -PROPERTY NEVER REVERT TO SETTLOR -WATCH OTHER ATTRIBUTION ALSO *SETTLOR LINEAR RELATIVE TO BENEFICIARIES *KEY MATTERS TO NOTE -SETTLOR CAN BE TRUSTEE -SETTLOR SHOULD NOT BE BENEFICIARY -TRUST SHOULD BE IRREVOCABLE AND NO VARIATION -SETTLOR PAY COSTS TO ESTABLISH TRUST