Our Blog - Segal Insider

Senior Accountant, Assurance

Segal LLP is a rapidly growing mid-size accounting, tax and business advisory firm headquartered in midtown Toronto. Segal is committed to growth by investing in our team, providing continuous learning and a positive, supportive entrepreneurial work environment all with a focus on providing clients best in class client service.

The Senior Accountant, Assurance is responsible to apply sound practices and methodologies to conduct audits and review engagements. Reporting to Partners, Principals and Managers, the Senior Accountant, Assurance leads the fieldwork team, coaches and mentors junior team members and is a self-managed professional motivated to provide clients an outstanding level of client service within a team-based environment.

Key Responsibilities

  • In consultation with the engagement manager plans, organizes, and controls multiple responsibilities and resources to achieve Audit, Review and Notice to Reader engagement objectives.
  • Prepares engagement file, financial statements, and appropriate income tax returns
  • Monitors multiple projects and deadlines
  • Builds and nurtures strong working relationships with client management and peer client levels
  • Delegates effectively and contributes to a motivated and empowered work team. Shares and transfers knowledge within the team.

Professional Skills and Education

  • CPA, CA or degree qualification and relevant professional accreditation
  • Three or more years’ experience in a public accounting firm
  • Demonstrated technical knowledge and skills with experience in ASPE and/or IFRS reporting standards
  • General knowledge of personal and corporate tax
  • Strong interpersonal and relationship building skills
  • Developing strong project management capabilities
  • The ability to coach, motivate and direct a team of people
  • Team player with a positive ‘can do’ approach
  • Creative problem solving and experience in delivery of quality client service
  • Excellent verbal and written communication skills

This position represents a significant opportunity for those looking to advance their career by playing a major role in a growing organization, and who have the curiosity and interest in exposure to a broad range of clients, industries, and assignments.

To submit your resume for this position, please contact us by email here.

Tax Manager

Segal LLP is a rapidly growing mid-size accounting, tax and business advisory firm headquartered in midtown Toronto. Segal is committed to growth by investing in our team, providing continuous learning and a positive, supportive entrepreneurial work environment all with a focus on providing clients best in class client service.

As a member of our Tax Team, you will advise our clients by contributing to strategic tax planning and client management initiatives. As Manager, you’ll work as part of a team to collaborate, design, and solve complex business issues from strategy to execution.

Responsibilities

  • Participate in income tax planning engagements
  • Prepare and/or review tax planning memos including reorganizations, estate planning, cross border structures
  • Prepare detailed tax analysis on tax issues
  • Review complete corporate, personal, trust and partnership returns
  • Work with both the tax group partners and accounting/auditing group partners
  • Work efficiently and effectively within client engagement parameters and prioritize and balance multiple files
  • Supervise a team, delegate tasks, and promote teamwork
  • Mentor, train, and delegate work to junior team members in the Tax team.
  • Participate in the training of staff to support their growth, knowledge, and professional development.

Qualifications

  • CPA designation.
  • Completion of CPA Canada In Depth Tax Course or Master of Taxation is required
  • Demonstrated experience in tax and estate planning for business owners or high net worth individuals
  • Strong technical background in Canadian income tax; experience with corporate tax return preparation and review, tax research, and drafting letters would be considered an asset
  • Ability to prepare effective research and planning memos independently and as part of a team.
  • Can work under pressure, be decisive, exercise good judgment and common sense
  • Working proficiency in Microsoft Suite including Word, Excel, PowerPoint, is essential.
  • Experience with Caseware and TaxPrep (or similar tax preparation software) is expected.
  • Ability to recognize and analyze problems, propose sound alternatives and conclusions
  • Strong interpersonal and relationship building skills and a demonstrated ability to develop and nurture strong relationships with clients
  • Excellent verbal and written communication skills
  • Team player with a positive ‘can do’ approach.
  • Creative problem-solving ability.
  • Organized and able to meet multiple project deadlines while being detail oriented.
  • Strong commitment to professional client service excellence

To submit your resume for this position, please contact us by email here.

2021/2022 Tax Series for Accountants

We are pleased to announce the return of Segal’s Tax Series For Accountants for 2021/2022, hosted by our Tax Partner, Howard L. Wasserman.

We invite any interested accounting professionals to join us for a great seminar series, covering a range of relevant tax topics.

The series will span over the following four days:

  • Wednesday, October 6th, 2021
  • Wednesday November 3rd, 2021
  • Wednesday December 1st, 2021
  • Wednesday, January 26th, 2022

To ensure the safety of our speakers and guests, we have made the decision to host all four seminars online. The sessions will be presented live, giving attendees the opportunity to ask questions.

If you are unable to “attend” the live presentation, don’t worry, the recorded sessions will be available to watch at your convenience.

We hope you will join us again this year and we look forward to seeing you!

The event is $300 (plus HST) to attend. This includes four 2 hour sessions and learning materials.

Each seminar will run from 8:30 am to 10:30 am. The Tax Series will be hosted online and the link to attend will be sent to attendees the week prior.

CPD: Attending these 4 sessions will provide 8 hours of verified CPD hours with an attendance certificate provided.

Wednesday, October 6th, 2021

  • Budget 2021 Update
  • Update on Impact of COVID 19 Tax/Subsidy Rules
  • Update on TOSI Issues
  • Bill C-208 Intergenerational Transfers

Wednesday, November 3rd, 2021

  • Integration and Tax Rates
  • Year-End Planning Including Salary/Dividends
  • Personal and Corporate Taxation of Earning US Income
  • Discussion/Impact of Proposed US Tax Rules

Wednesday, December 1st, 2021

  • Estate Freeze and Re-freeze Considerations
  • Treaty Filings – Non Resident Corporations

Wednesday, January 26th, 2022

  • Purification and Capital Gains Exemption
  • Safe Income and Dividends
  • Purchase/Sale Considerations

Tax Specialist

Segal LLP is a rapidly growing mid-size accounting, tax and business advisory firm headquartered in midtown Toronto. Segal is committed to growth by investing in our team, providing continuous learning and a positive, supportive work environment all with a focus on providing clients best in class client service.

As a member of our Tax Team, you will advise our clients on corporate and personal tax planning, deferral strategies, financing structures, employee compensation, owner-managed remuneration or a range of other complex tax issues. You will have the opportunity to resolve client issues directly with the client, the CRA and other government or regulatory agencies.

Responsibilities

  • Work with partners and the tax team on client engagements and deliverables, and practice development initiatives.
  • Support Partners, Principals and Managers in all aspects of personal and corporate tax initiatives
  • Prepare notices of objection for corporate and personal clients and negotiate the same with the Appeals Division.
  • Prepare/review complex tax returns (T1, T2, and T3 returns) and tax elections as required.
  • Mentor, train, and delegate work to junior team members in the Tax team.
  • Research tax issues
  • Prepare calculations to support tax analysis

Qualifications

  • CPA designation; ideally enrolment in, the CICA In-Depth or M. Tax.
  • Bachelor’s Degree (or equivalent experience) from an accredited institution in Accounting, Business Administration, or related field.
  • Ability to prepare effective research and planning memos independently and as part of a team.
  • Several years of tax experience, working with owner-managed clients.
  • Excellent understanding of basic tax concepts and files.
  • Strong interpersonal and relationship building skills.
  • Team player with a positive ‘can do’ approach.
  • Creative problem-solving ability.
  • Excellent verbal and written communication skills
  • Working proficiency in Microsoft Suite including Word, Excel, PowerPoint, is essential.
  • Be organized and able to meet multiple project deadlines while being detail oriented.
  • Strong commitment to professional client service excellence

To submit your resume for this position, please contact us by email here.

Family Transfers of Small Businesses, Family Farms and Fishing Corporations

Bill C-208 is a recent private members bill that tries to facilitate intergenerational transfers of a business between family members in a more tax friendly manner. In the past, a parent could not claim the capital gains exemption when they sold shares of a small business corporation to a corporation owned by their children or grandchildren.  However, that same parent could sell shares of their small business corporation to an arms-length corporation and claim the capital gains exemption.  These anti-avoidance rules can be found in section 84.1 of the Income Tax Act (“the Act”).

Even though Bill C-208 recently received royal assent, the current minority government is concerned that it has created unintended tax avoidance loopholes. In a surprise announcement on June 30, 2021, the Department of Finance (“Finance”) stated that it will introduce new legislation to clarify these amendments will not apply until January 1, 2022.  This put Bill C-208 in a state of “tax limbo” in that it is law, but the Department of Finance has communicated that it wants to change how this law is applied.

On July 19, 2021, Finance backtracked on its previous announcement by indicating that it will accept Bill C-208 as the current law since it was passed by Parliament and received Royal Assent. Finance has stated that “the federal government is committed to facilitating genuine intergenerational share transfers, while preventing tax avoidance that undermines the equity of Canada’s tax system.” Clearly, the current government does not like how Bill C-208 is drafted and they intend on making amendments which would take effect as of the later of either November 1, 2021 or the date of publication of the final draft legislation.

In the July 19, 2021 announcement, Finance identified “surplus stripping” (i.e., converting dividends to capital gains) as one loophole that Bill C-208 may inadvertently permit. It also provided a list of the following issues the amendments to Bill C-208 would address:

  • The requirement to transfer legal and factual control of the corporation carrying on the business from the parent to their child or grandchild;
  • The level of ownership in the corporation carrying on the business that the parent can maintain for a reasonable time after the transfer;
  • The requirements and timeline for the parent to transition their involvement in the business to the next generation; and
  • The level of involvement of the child or grandchild in the business after the transfer.

The July 19, 2021 announcement is welcome news for Canada’s small business community. It has eliminated the uncertainty that previously existed from Finance’s earlier comments. It has also provided us with more insight into the federal government’s concerns for tax avoidance. Taxpayers now have a small window of opportunity to complete intergenerational share transfers using the existing rules in Bill C-208. Since Finance has publicly stated their concerns with the legislation it is recommended that genuine transactions take place over the next several months.

In order to qualify for the capital gains exemption, shares of a private company must be qualified small business corporation (“QSBC shares”). Upon the sale of QSBC shares, an individual can claim their lifetime capital gains exemption (“LCGE”) which is currently $892,218 (indexed each year) and $1 million for family farm or fishing corporation shares.  The old rules in section 84.1 of the Act re-classified the proceeds from the purchase of shares by a related corporation to be a dividend instead of proceeds.  Therefore, the related vendor was unable to claim the capital gains exemption.  The new legislation has been introduced to limit the application of 84.1 of the Act and also allow for certain reorganizations between siblings.

Reorganization Amendments

Under current paragraph 55(5)(e) of the Act siblings are deemed not to be related for the purposes of certain reorganizations. This means that where siblings want to take their holdings in a  shared company into two separate companies, they were limited by the rules of subsection 55(2) of the Act. This provision is an anti-avoidance rules intended to prevent the conversion of an amount that would normally be a taxable capital gain into a tax-free intercorporate dividend.  The amendment in Bill C-208 states that siblings are no longer considered to be “not related” for the purposes of these reorganizations if the shares of the corporation involved are QSBC shares, family farm or fishing corporation shares.  These rules will not allow for the separation of companies with investments or rental assets.

Section 84.1 Amendments

As noted above, 84.1(1) of the Act has a set of rules that converts what would otherwise be a capital gain into a dividend, thereby eliminating the ability to claim the capital gains exemption.  The new rules will apply where the following apply:

1. The exchanged shares are QSBC shares or shares of a family farm or fishing corporation.

2. The purchaser corporation is controlled by one or more children or grandchildren (aged 18 or older) of the vending taxpayer.

3. The purchaser corporation does not dispose of the exchanged shares within 60 months of the purchase.

Where all of these conditions apply, the taxpayer and purchaser corporation will be deemed to be dealing at arms-length so that the negative implications of 84.1 of the Act won’t apply.  The vendor will be able to claim the CGE if eligible.

Where the corporation being sold has taxable capital in excess of $10 million, the ability to claim the capital gains exemption will be reduced until such time as the taxable capital is $15 million or more.  At that point, the vendor will not be able to claim the capital gains exemption.  One of the other limiting factors is that the taxpayer must provide to CRA with an independent assessment of the fair market value of the shares being sold and an affidavit signed by the taxpayer and by a third party attesting to the disposal of the shares.  These rules are in place to ensure that a taxpayer does not transfer shares to a child as a “paper transaction” where in essence  the transfer to the child has not really occurred.  This also ensures that the value of which the transfer occurs is a reasonable one.

Planning Ideas

As noted above, the changes in Bill C-208 only apply where the shares sold are shares of a QSBC.  In order to be a QSBC, the following tests must be met:

1. The shares must have been owned continuously for 24 months or more;

2. The company must be a CCPC;

3. 90% or more of the fair market value of the of the assets must be used in an active business in Canada.

4. Throughout the 24 month period prior to the share sale, more than 50% of the fair market value of the assets must have been used in an active business in Canada

The asset tests are very important to monitor.   If a corporation has accumulated assets, such as cash, investments, loans receivable or rental properties, the shares may not qualify as QSBC shares.  In planning to remove these redundant assets, there still may be tax because of the current provisions of section 55 of the Act.  Having said that, it may be worthwhile to pay some capital gains tax on the removal of certain assets in order to be able to access the capital gains exemption and possibly the multiplication of the capital gains exemption.

Please contact your Segal advisor to discuss the planning required in your situation.