Should Your Client's Vacation Property Ever Be Held by a Corporation?

Live date December 2025
Live time 12:00 p.m. – 1:30 p.m. ET
Duration 130chat minutes

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Registering multiple people? Volume discounts from 10% to 30% apply automatically at checkout.

Canadian autumn forest

See what to expect

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Live session + Q&A

105 minutes of teaching plus 15 minutes of live Q&A discussion.

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Recording access

The webinar recording will be available shortly following the live event.

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Detailed slide deck

Includes tax tables, worked examples, planning notes, technical references, and supporting resource materials.

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CPD certificate

A CPD certificate is available after successful quiz completion.

Real-world planning question

The client paid with 90-cent dollars. Fifteen years later, what did the structure actually cost?

A profitable operating company bought a Muskoka property for roughly $500,000 about fifteen years ago. It was never rented, the family used it, and no one advised on the structure at the time. The imputed shareholder benefit across those years reaches roughly $5,000,000 against an economic gain of about $3,500,000, leaving the shareholder roughly $925,000 behind once tax, interest and extraction are counted.

What we'll work through

01

Why Clients Do It, and What the Structure Costs

  • Corporate dollars against after-tax personal dollars on the same purchase
  • Phantom income: cash tax on an asset that earned no revenue
  • Corporate ownership and the principal residence exemption — ITA 54, 40(2)(b)
  • Whether annual inclusions build any basis, and where basis finally arrives
02

Classifying the Property

  • Personal-use, mixed-use and genuinely passive — three different regimes
  • Why “do you rent it out?” is the wrong place to stop
  • The absence of any published CRA classification test
  • Primary purpose in the case law: Fingold, Laliberté, Jackman
03

Subsection 15(1) and the Computation

  • The operative words, and the carve-outs that do not reach a cottage
  • Why a 15(1) inclusion costs more than the same value paid as a dividend
  • Rate of return, corporate-paid operating costs, amounts actually paid
  • Availability rather than nights used — Arpeg
  • Rates that must not be substituted for the normal return on capital
04

Borrowing, Shareholder Loans and the Single-Purpose Corporation

  • Subsection 15(2) when the shareholder borrows to buy personally
  • The repayment test: the one-year rule and the series condition
  • The withdrawn single-purpose corporation position, and who remains grandfathered
  • Shareholder-loan funding: what it reduces — and what remains
  • Identifiability and continuity — the two traps in that relief
05

Getting the Property Out

  • Appropriation at fair market value against a wind-up distribution
  • Sequencing the surplus pools, cheapest money first
  • Capital dividend account mechanics and T2054 timing
  • Land transfer tax and GST/HST screening on the way out
06

Reach-Back, Disclosure and Finding the Files

  • The normal reassessment period, and the route beyond it
  • Why the assessable-years assumption drives the entire client number
  • Gross negligence and statute-barred reassessment as separate tests
  • Voluntary disclosure tiers, and what moving first is worth
  • The balance-sheet screen that surfaces these files across a client base

The Bigger Questions Behind a Corporate-Owned Cottage

The facts involve one cottage inside one operating company. But the same questions can arise whenever a corporation holds property for a shareholder’s personal use — a condo, a boat, an aircraft or a vehicle.

Characterization Comes Before Computation

Whether a property is personal-use, mixed-use or genuinely passive changes which regime applies, not merely the size of the inclusion. Most files turn on that question long before any arithmetic begins.

An Assumption Can Outweigh the Arithmetic

Reach-back and the rate of return are assumptions, not findings. Change either and a carefully built client number moves materially, which is why both belong on the page beside the result.

Where There Is No Test, There Is Still Work

Not every classification question comes with a published CRA test or a case directly on point. That makes judgment, assumptions, pricing and contemporaneous documentation more important — not less.

Learn with Kim and Jay

Kim G C Moody

Tax Authority

Kim G C Moody

LinkedIn

FCPA, FCA, TEP

  • Former Chair, CBA/CPA Joint Committee
  • Former Chair, Canadian Tax Foundation
  • Parliamentary committee witness
Jay Goodis

TAX STRATEGY & OPTIMIZATION

Jay Goodis

LinkedIn

CPA, CA

  • CPA Ontario Emerging Leader
  • Parliamentary committee witness
  • National tax & keynote speaker

Questions before purchasing?

Yes. Discounts range from 10% to 30% based on the number of people registered. The volume discount applies automatically at checkout as additional registrations are added.

You'll receive a confirmation email for your registration, along with a link to access the live session.

If you cannot attend live, the recording will be made available in your CTM account shortly after the session ends, so you can watch on demand.

Yes. The detailed slide deck and supporting materials will be posted shortly before the live session. When the recording is available, you'll be notified by email.

You will have access to the recording and course materials through your CTM account for one year. CTM members can access course materials while their membership is active.

Yes. A CPD certificate is available after successful quiz completion.

Yes. We will take questions during the live Q&A portion after the teaching session.

No. CTM members don't need to register for live sessions. We'll email you the link to join automatically. If you don't see it, check your spam folder or contact us.

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