High-Net-Worth Tax Strategy Stratégie Fiscale pour Grandes Fortunes

The Integrated Tax Position

High-net-worth Canadians rarely have a simple tax position. The typical client has a personal T1 return, one or more corporate T2 returns for operating and holding companies, one or more trust T3 returns, and potentially provincial and foreign tax filings. These filings are not independent — they interact in ways that create planning opportunities and planning risks that are invisible if each return is prepared in isolation.

Income Splitting in the Post-TOSI Environment

The Tax on Split Income rules, significantly expanded in 2018, have constrained many traditional income splitting strategies. However, legitimate income splitting remains available through spousal RRSP contributions, pension income splitting, capital gains allocation to family trusts with eligible beneficiaries, and salary or dividend payments to family members for genuine services rendered. St. Lawrence Gate advises on the full range of compliant income splitting strategies available to your specific family structure.

Capital Gains Planning

With the capital gains inclusion rate at two-thirds for gains above $250,000 as of 2024, the timing and character of capital gains transactions has become more significant. Strategies including lifetime capital gains exemption utilization, capital gains reserve elections, section 85 rollovers, capital gains stripping arrangements, and charitable donations of appreciated securities all warrant evaluation in the context of planned dispositions.

Alternative Minimum Tax

The federal Alternative Minimum Tax, significantly expanded in 2024, can affect high-income Canadians in years when they make large charitable donations, exercise options, or undertake certain tax shelter investments. St. Lawrence Gate models AMT exposure as a standard component of any tax year with unusual income or deduction events, ensuring that planning strategies are evaluated with full awareness of their AMT implications.