Wealth Signal
Edition · Edition 047 / Transferable to you · Item 01

The offshore trust-over-holdco stack

Does not transfer

The Jersey–Cyprus and Mexican-trust chains buy two things that are simply unavailable here: separation of the settlor from the economic interest for disclosure purposes, and a tax-neutral situs. Canada closes both doors. A Canadian-resident settlor who retains a benefit is caught by the attribution rules, and a non-resident trust with a Canadian resident contributor is generally deemed resident in Canada under section 94 of the Income Tax Act, which removes the point of putting it offshore at all.

What does carry over is the shape, not the geography: an Ontario holding company beneath a discretionary family trust, with future growth in the operating company frozen into the trust. That is a domestic structure with domestic rules, and it is the version worth asking about.

THIS WEEK · Pull Geomechanica’s share register and write one page: who holds what class, and what each class is entitled to on a sale. Most structure conversations stall because that page does not exist.
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