Wolfe D. Goodman, Q.C., Lawyer
Editor-in-Chief, Conference Speaker
Federated Press Contributions
| Editor-in-Chief, Goodman on Estate Planning (EP) 1992– |
| Speaker, "Marital Breakdown, as Viewed by an Estate Planner", Marriage and Money Conference, Toronto, September 1, 1998 |
| The most recent articles from Dr. Goodman's more than 300 contributions to date: |
| "Conservation Easements and Other Ecological Gifts" (2000) 8 EP 640 |
| "Commentary on Some Revenue Canada Rulings Regarding Charitable Gifts" (2000) 8 EP 642 |
| "Some Principles of Cross-Border Estate Planning Strategies" (2000) 8 EP 648 |
| "Double Taxation Problems Upon Cessation of Canadian Residence" (2000) 8 EP 652 |
| "Cessation of Canadian Residence Without Acquiring U.S. Residence in the Year" (2000) 8 EP 653 |
| "Can a Transfer to a Revocable Inter Vivos Trust Ever Avoid Both a Deemed Disposition at Fair Market Value and Payment of Probate Fees at Death?" (2000) 8 EP 654 |
| "Non-Resident Trust Earning Dividend Income From Foreign Affiliate Out of Affiliate's Active Business Income" (2000) 8 EP 655 |
| "Inapplicability of Offshore Trust Rules in Prescribed Circumstances" (2000) 8 EP 656 |
| "Attempting to Avoid Deemed Realization at Death by Providing in Shareholders' Agreement for Automatic Redemption of Shares One Day Before Death" (2000) 8 EP 657 |
| "Effect of Treating a Beneficiary of a Mutual Fund Trust as Not Dealing at Arm's Length With the Trust" (2000) 8 EP 659 |
| "Proposed Amendments to English Trustee Act" (2000) 8 EP 660 |
| "A Fresh Look at Charitable Remainder Trusts" (2000) 9 EP 664 |
| "When Estate Planning Has Gone Wrong What, if Anything, Can Be Done About It?" (2000) 9 EP 669 |
| "U.S. Estate Tax Liability for Property in Canada Owned Jointly by a Canadian Citizen and his U.S. Citizen Spouse" (2000) 9 EP 674 |
| "Closing a "Loophole" in the Japanese Gift and Inheritance Tax System" (2000) 9 EP 676 |
| "The Dangers Involved When a Self-Directed RRSP Invests in U.S. Securities" (2000) 9 EP 677 |
| "Some Perils of Investing in U.S. Mutual Funds" (2000) 9 EP 677 |
| "Incorporating a Foundation for Charitable and Non-Charitable Purposes" (2000) 9 EP 679 |
| "Does the Romkey Decision Imply a Serious Attack on Estate Freezing" (2000) 9 EP 680 |
| "Avoiding Deemed Realization on 21st Anniversary of Trust by Conveying Remainder Interest in Real Property to Capital Beneficiary" (2000) 9 EP 681 |
| "Canadian Citizen Dies Domiciled and Resident in U.S. Owning Only U.S. Situs Property, Left to Canadian Citizen Spouse — Applicability of Canada-U.S. Convention" (2000) 9 EP 682 |
| "How U.S. Law Deals with Variations of Trust Involving Incapacitated Beneficiaries" (2000) 9 EP 684 |
| "Alter EGO Trusts and Joint Spousal Trusts" (2000) 9 EP 688 |
| "Transfer of Appreciated Property to Resident Spousal Trust Before Transferor Becomes a Non-Resident" (2000) 9 EP 691 |
| "Forcing the Settlor of an Offshore Asset Protection Trust to Repatriate the Trust Assets by Contempt Proceedings" (2000) 9 EP 693 |
| "Indefeasibly Vested Interests" (2000) 9 EP 694 |
| "Offshore Investment Funds — Effect of 1999 Federal Budget" (2000) 9 EP 696 |
| "What Happens When a Court Puts Pressure on Trustees of a Discretionary Trust to Make a Payment to an Object of the Trust?" (2000) 9 EP 698 |
| "Liability of Non-Arm's Length Transferee for Transferor's Income Tax Liability — The Biderman Case" (2000) 9 EP 700 |
| "Whether a Bequest in a Will to a Private Foundation to Be Established by Executors Qualifies for Credit in Year of Death" (2000) 9 EP 701 |
| "An Estate Freeze in Which a Child Freezes her Equity Shares in Favour of her Parents" (2000) 9 EP 702 |
| "Policies Effected with Non-Canadian Insurers — Draft Legislation of June 22, 2000" (2000) 9 EP 703 |
| "Can a Donor of Certified Cultural Property Retain a Right of Possession During Lifetime?" (2000) 9 EP 705 |
| "Another Situation Where Probate Fee Planning Can Go Wrong" (2000) 9 EP 706 |
| "How Much Do the Guarantees in Segregated Fund Life Insurance Policies Cost?" (2000) 9 EP 707 |
| "Deliberate Depletion of Husband's Property Shortly Before Death, in Order to Avoid Equalization Claim by Wife" (2000) 9 EP 708 |
| "Election by Trust Not to Deduct Income Payable to Income Beneficiary and to Have Such Income Taxed in Hands of Trust" (2000) 9 EP 709 |
| "Attack on a Trust as a Sham" (2000) 9 EP 709 |
| "Changes in Trustee Act — Delegation of Discretionary Investment Management" (2000) 9 EP 710 |
| "New Attacks on Offshore Trusts" (2000) 9 EP 710 |
| "A Letter to the Minister of Finance Regarding the Proposed Offshore Trust Rules" (2000) 9 EP 712 |
| "When Can the CCRA Enforce a U.S. Tax Liability Under Article XXVI-A of the Convention?" (2000) 9 EP 716 |
| "Significant Recent Developments in Trusts and Trust Taxation" (2000) 9 EP 718 |
| "Cross-Border Planning for U.S. Citizens Resident in Canada" (2000) 9 EP 720 |
| "Attacking an Offshore Trust on the Basis of Sham" (2000) 9 EP 722 |
| "Using Discretionary Classes of Shares to Benefit a Spouse" (2000) 9 EP 723 |
| "Splitting a Capital Gain with One's Spouse — Applicability of General Anti-Avoidance Rule" (2000) 9 EP 724 |
| "Effects of Federal Mini-Budget of October 15, 2000 on Charitable Gifts" (2000) 9 EP 725 |
| "Using an Alter Ego Trust as a Charitable Remainder Trust" (2000) 9 EP 727 |
| "Can Nil Partnership Income Be Allocated So as to Show a Profit for One Partner and a Loss for Another?" (2000) 9 EP 731 |
| "Proposed Changes in the Canada-U.S. Income Tax Convention Affecting Emigrants From Canada" (2000) 9 EP 733 |
| "The Decision in Canadian Pacific Ltd. on the General Anti-Avoidance Rule" (2000) 9 EP 734 |
| "A Swiss Case Recognizing a Foreign Trust, But Treating it as a Sham" (2000) 9 EP 736 |
| "Canadian Resident with U.S. 401(k) Plan Who Wishes to Leave Funds to Canadian Charities" (2000) 9 EP 736 |
| "Payment to Income Beneficiary in Satisfaction of Beneficiary's Interest, Financed by Loan to Trust" (2000) 9 EP 737 |
| "Coping with Deemed Realization of Trust Property on the 21st Anniversary" (2001) 9 EP 740 |
| "Proposed Rules for Taxation of Trusts Published on December 17th, 1999" (2001) 9 EP 750 |
| "Can a Capital Loss Arise on Expiry of a Life Interest in Property?" (2001) 9 EP 755 |
| "Calculation of the Adjusted Cost Base of Identical Properties for Purposes of the Lifetime Capital Gains Exemption" (2001) 9 EP 756 |
| "Can a Charitable Organization Safely Transfer Real Property to a Wholly-Owned Subsidiary for Development and Rental?" (2001) 9 EP 757 |
| "The Effect of a Non-Arm's-Length Assignment of an Employee Stock Option" (2001) 9 EP 758 |
| "Coping with the Proposed Legislation Affecting Investment by Canadian Residents in Offshore Mutual Funds" (2001) 9 EP 759 |
| "The Effect of Draft Legislation of June 22, 2000 on Emigrant Trusts" (2001) 9 EP 761 |
| "Recent Changes Affecting Inheritance Tax in Ireland" (2001) 10 EP 769 |
| "Calculating the Canadian Tax Liability of a U.S. Citizen Resident in Canada" (2001) 10 EP 770 |
| "Whether a Corporate Recipient Can Add Non-Taxable Portion of a Capital Gain's Dividend to Its Capital Dividend Account" (2001) 10 EP 770 |
| "Attribution of Income to a Spouse Who Provided Funds to Settle an Immigrant Trust" (2001) 10 EP 771 |
| "Balancing the Interests of Settlors and Trustees Regarding Access to Information and the Ability to Be Involved in a Controlling Interest in a Commercial Venture" (2001) 10 EP 772 |
| "The Effect of the Draft Legislation of June 22, 2000 on Offshore Estate Freezes" (2001) 10 EP 773 |
| "Can a Foundation Which Has Met Its Disbursement Quota Make Gifts to Foreign Charities?" (2001) 10 EP 775 |
| "An Unusual Application of Article XXIX-B of the Canada-U.S. Convention" (2001) 10 EP 777 |
Biography
| Educated University of Toronto B.Comm. 1946, S.J.D. 1976; Osgoode Hall Law School of York University LL.B. 1949 |
| Senior Partner, Goodman and Carr |
| Appointed Queen's Counsel 1968 |
| Called to the Bar of Ontario 1949 |
| Fellow, American College of Trust and Estate Counsel |
| Member, Executive Committee, International Academy of Estate and Trust Law |
| Consultant to the Auditor General of Canada |
| Member, Wealth Tax Working Group, Ontario Fair Tax Commission |
| Past Member, Minister's Advisory Council on the GST |
| Past Chair, Federal Sales Tax Advisory Committee; Ad Hoc Committee, Canadian Centre for Philanthropy working with the Department of Finance on income tax rules affecting charities |
| General Reporter, International Double Taxation of Inheritances and Gifts, 1985 London Congress, International Fiscal Association |
| Past Lecturer, Estate Planning, University of Toronto |
| Author, numerous publications on taxation and estate planning |
Practice Description
| Dr. Goodman's expertise in taxation and estate planning is the result of some 45 years of practice in these areas. He has advised various government departments and other agencies on taxation and estate planning. |
Address
| Goodman and Carr |
| Suite 2300 |
| 200 King Street West |
| Toronto, Ontario M5H 3W5 |
| Telephone: (416) 595-2353 |
| Telecopier: (416) 595-0567 |
| E-mail: wgoodman@goodmancarr.com |
| Web: www.goodmancarr.com |