Wealth Signal
Edition · Edition 039 / Transferable To You · Item 01

1. Doing the structural act long before the liquidity act

Transfers

This is the week’s one genuinely portable idea. Dines did the irreversible thing — converting away permanent voting rights — five weeks before anyone had a reason to look, and at a moment when it cost him nothing visible. The Canadian analogue is the estate freeze: exchange your common shares in the operating company for fixed-value preferred shares under section 85 or section 86 of the Income Tax Act, and issue new common shares to a family trust or a holding company, so that all future growth accrues outside your own estate.

Like the conversion, it is effectively one-way, and like the conversion its whole value depends on doing it before the growth it is meant to redirect. A freeze done after a valuation inflection redirects much less.

First step this week — commission a defensible, dated valuation of the company as it stands today. The freeze is only ever as good as the number you freeze at, and the number has to be supportable to a tax authority years later.
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