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Uses of Trusts in Estate Planning - Stewart McKelvey

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Seed<strong>in</strong>g <strong>Trusts</strong> (Cont’d)<br />

• Can be a powerful <strong>in</strong>come-splitt<strong>in</strong>g tool,<br />

but does require a private company to<br />

connect with<br />

• Caution: watch out for “corporate<br />

attribution” under 74.4 <strong>of</strong> the ITA <strong>in</strong><br />

respect <strong>of</strong> spouses and m<strong>in</strong>or children<br />

(“designated persons”) when the company<br />

is only a hold<strong>in</strong>g company that does not<br />

carry on as active bus<strong>in</strong>ess

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