Estate Freeze

Learn how to shift growth to the next generation while managing tax at death, preserving control, and avoiding common pitfalls.

Michael Cadesky explains the principles behind estate freezes, the strategies used to implement them, and the tax issues CPAs must understand when advising business owners.

On-Demand
On-Demand

2 Hours CPD
2 Hours CPD

Included in Archive
Included in Archive

Course Overview

Estate freezes are one of the most valuable tools in Canadian tax planning for family businesses. They allow the current owner to lock in today’s value and pass future appreciation to children or trusts. When used properly, a freeze can reduce tax at death, support succession planning, multiply the capital gains exemption, and prepare a company for future sale or transition.

However, freezes also create risks and planning challenges. Decisions around preferred share terms, trust involvement, valuation, remuneration, and the impact on TOSI rules can significantly affect outcomes. The program demonstrates how freezes can lead to double taxation if not coordinated with post-mortem planning, and how passive assets, RDTOH balances, or inappropriate structures may produce unwanted results.
Learning Objectives
1
Understand the core purpose of an estate freeze and how future growth is shifted
2
Recognize when a freeze is beneficial for succession, capital gains exemption planning, and estate tax reduction
3
Compare freeze structures such as Holdco freezes, Opco freezes, drop down freezes, and note freezes
4
Identify tax issues related to TOSI, attribution, valuation, and imputed interest

Seminar Snapshot

Date Recorded
October 10, 2024
Presentation
Yes
Slides
Yes
Detailed Notes
Yes
Technical Corner
YES
Teach Test
No
Resources
Yes
Included in Archive
YES

ESTATE FREEZE

Duration
2 hours + Optional Q&A Recording
CPD CPD Certificate
Category
Estate Planning
Estate Freeze provides a clear, practical explanation of how a freeze shifts future corporate growth to the next generation while locking in today’s value for the parent. The course outlines the key reasons freezes are implemented, including reducing tax at death, multiplying the capital gains exemption, managing TOSI exposure, and supporting long term succession plans. Participants learn how freezes operate in real client situations, how preferred shares, common shares, control shares, and notes work together, and how different freeze formats such as Holdco freezes, Opco freezes, drop down freezes, and note freezes achieve varying results. The session also highlights the planning considerations that influence outcomes, including valuation decisions, cash flow needs, attribution risks, trust involvement, and ownership of passive or investment assets that complicate freeze design.

The program also explains the potential pitfalls that can arise when freezes are implemented without full planning. CPAs will learn how double taxation occurs in certain corporate structures, why post mortem planning must be considered in advance, and how pipelines, wind ups, and share redemptions interact with freeze results. The material covers TOSI rules, excluded share requirements, section 74.4 imputed interest, family law exposure, timing issues such as freezing too early or too late, and the importance of coordinating freezes with wills, shareholder agreements, and life insurance. By understanding the strategy from start to finish, CPAs will be equipped to design freezes that achieve their goals and avoid the common errors that lead to poor tax outcomes.
After completing this program, you will be confident with:
  • Identifying which freeze structure is suitable for a given situation
  • Recognizing TOSI, attribution, and valuation issues early
  • Evaluating post mortem planning steps that affect freeze outcomes
  • Understanding the roles of preferred shares, common shares, control shares, and notes
  • Reviewing trust involvement and avoiding attribution issues under subsection 75(2)
  • Modeling the cash flow and remuneration needs of the senior generation
This course is essential if you are responsible for:
  • Advising family businesses on succession planning
  • Structuring freezes for clients who expect significant future growth
  • Planning for capital gains exemption multiplication
  • Managing the interaction between corporate planning, wills, and estate strategies
  • Assessing freeze structures for TOSI exposure, creditor protection, and long term tax outcomes

Meet Your Presenters

Michael Cadesky

Michael Cadesky

FCPA, FCA, FTIHK, CTA, TEP (EMERITUS)

Michael Cadesky is the managing partner at Cadesky Tax and a committed contributor to the tax and accounting professions since 1980, earning the title of Fellow from CPA Ontario. He is a past governor of the Canadian Tax Foundation, past chair of STEP Canada and STEP Worldwide, and past chair of the CPA Canada Tax Committee for Small and Medium-Sized Enterprises. Michael is also the co-author of 11 books on tax subjects and the author or co-author of numerous papers and articles on Canadian and international taxation.

Hugh Woolley

Hugh Woolley

CPA, CA, TEP

Hugh Woolley is an independent tax consultant who has taught income tax for over 30 years for a number of different professional organizations. Hugh has written courses for CPA Canada and over 10 papers for the B.C. Tax Conference as well as papers for the CTF's National Tax Conference and STEP Canada's National Conference. From 1990–1992 he worked at the CRA's Rulings Directorate in Ottawa writing "butterfly" tax rulings. Hugh is a past Governor of the Canadian Tax Foundation.

Frequently Asked Questions
Once you complete your purchase, you will create your account if you haven't already. You can access the course anytime through our platform. All Cadesky Tax Seminars programs come with one-year access.
Yes. This course is eligible for verifiable CPD hours for Canadian CPAs. A downloadable Certificate of Completion will be available once you complete all required modules.
Our programs are designed for CPAs and tax professionals who want to deepen their technical expertise. While no prerequisites are required, a working knowledge of Canadian tax will help you get the most out of the material.
On-demand courses include the full video presentation, downloadable slides, and additional resources mentioned in the Seminar Snapshot (Technical Corner, teach test, checklists).
Yes. You will have unlimited access to the course materials within the 1-year access period, so you can revisit the content anytime to refresh your knowledge.

Trusted by CPAs and Tax Professionals across Canada