Estate Freeze
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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.
Course Overview
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.
Seminar Snapshot
ESTATE FREEZE
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.
- 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
- 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 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 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.
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This is a first time for me as well. Your firm was recommended to by one of my friends. Great source of information.
Thank you Mike, Hugh and team! I enjoyed the practical and realistic solutions to various tax issues.
Thank you ALL for such high quality courses and answering the questions in detail! So glad I found you guys!
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Thank you for the wonderful presentation, materials, and handling of queries as always.
This is my first time taking the Cadesky Tax Seminars. I am learning a lot and watching archived courses too. You have done a great job. Thank you so much!
I really enjoy your seminar series. Your presentations are extremely thorough and you explain complex tax issues very clearly.
The presentations are relevant. The material is easy to follow. Worked examples are excellent. It is a great value.

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