Getting money out of your corporation can be expensive.
Shareholders of Canadian-controlled private corporations (CCPCs) face high combined corporate and personal rates on distributed profits. The structure gives shareholders a lower-cost way to get money out of the corporation and into their hands personally.

Who this is for
You own a CCPC; Opco, Holdco, or both, with high income and/or retained earnings you’d rather have in your hands than on the balance sheet. You’ve already used the obvious levers. Salary and dividend mix, the capital dividend account, income splitting where TOSI allows it. That’s when this strategy shines.
What changes
The deduction can reduce taxable corporate income and in the process help lower the overall cost of getting funds from the corporation into the shareholder’s hands. There’s no holding period or market exposure. The right structure depends on your corporation’s safe income, integration position, and overall tax profile so it’s best coordinated with your accountant. My team is happy to work with them directly.
What it doesn’t do
It doesn’t change the corporate-level tax already paid on the profit. It doesn’t remove issuer risk. The company has to complete its eligible exploration spending on time, or the tax benefits can be reduced or denied, in whole or in part.
Questions
The corporation is the subscriber and corporate funds are used to fund the transaction.
Yes. The transaction always creates a capital gain and like a personal capital gain, only half is taxable. The other half of the gain is credited to the company's Capital Dividend Account (CDA) which then allows the shareholder to take the funds out tax-free. *** CAUTION: before removing funds via the Capital Dividend Account, check with the CRA to confirm the balance and note that any capital losses incurred within the company will offset in the CDA.
CCPCs, especially HoldCo's are ideal candidates for flow-through shares as their tax rate can exceed 50%. Same thing for an OpCo with income in excess of the active business income threshold.
Once the account and sunscription documents are in hand and funds are wired to our Trust Account, a transaction typically completes in an afternoon wioth the net proceeds of the transaction returned to the account that funded the transaction within a few days of closing. Timing is driven by when offerings become available. We usually have a queue and fill orders on a first-come, first-served basis.
Yes, I'm happy to speak with your acocuntant or any other trusted individual about the transaction. You might also direct them to this website in advance of a call.
Start with the Primer.
A guide to the tax benefits and mechanics of flow-through shares. One transaction, completely outlined, start to finish. It answers much of what people ask me at the start of their investigation.

No call required. I may send occasional writing on the same topic. Unsubscribe any time.
Ask a question, or book a meeting.
If you’d rather I speak with your accountant first, send them the For Accountants page. I’m happy to take it from there.


