Structural Outcomes

Case Studies

Real structural outcomes. Names and identifying details withheld to preserve confidentiality. The architecture, however, is real.

Tax Architecture01

$390K

Year 1 Tax Saving

What Is the Absence of Structure Costing This Physician?

The Challenge

Ontario Medical Corp with $689K active income, Manitoba HoldCo rental AAII grinding down the SBD limit, no IPP despite 4 years of eligible T4 history, no estate freeze, and TOSI risk on HoldCo dividends to spouse. Annual family tax: $618K.

The Outcome

Full fiscal architecture delivered $390,708 in Year 1 savings including IPP past service buyback — reducing family tax from $618K to $227K. Cumulative 5-year saving: $2.06M.

IPPCOLI / AAII ShieldEstate FreezeHoldCoTOSI AuditSBD Protection
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Real Estate02

$105K

Annual Tax Saving

12 Properties. 2 Corporations. Why Is This Realtor Still Overpaying?

The Challenge

Solo realtor with active PSB risk under ITA s.125(7), $240K personal rental income taxed at Manitoba's 50.4% top rate, no HoldCo, unresolved TOSI and attribution on PropCo dividends, and no IPP or estate structure.

The Outcome

Blueprint reduced annual family tax from $248K to $143K. S.85(1) rollover of 8 personal properties, PSB documentation, HoldCo incorporation, and estate freeze deployed. 5-year saving: $580K.

PSB Mitigations.85(1) RolloverHoldCoTOSI FixIPPEstate Freeze
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Business Structuring03

$54K

Annual Tax Saving

The Law Society Restricts the Shares. It Does Not Restrict the Architecture.

The Challenge

Manitoba lawyer with Law Society voting share restriction preventing direct income splitting. Spouse earning $0 from the corporation, no IPP established, dormant PropCo costing $2,500/year with zero return, and no estate plan.

The Outcome

Architecture found every dollar the rules permit: $40K spousal salary, $22K IPP deduction, optimized T4, and HoldCo surplus deferral. Annual tax from $84K to $30K. 5-year saving: $299K.

Spousal EmploymentIPPSalary OptimizationHoldCoEstate FreezePropCo Review
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Wealth Architecture04

~$30K

Annual Tax Saving

Two Incomes. Three Children. Two Investment Properties. No Structure.

The Challenge

Household earning $310K combined as T4 employees — neither can incorporate. Two investment properties taxed at Manitoba's 50.4% top rate, no RESPs for 3 children (eldest approaching 17-year CESG deadline), no wills, no structure.

The Outcome

RESP action preserved CESG grants before eligibility expired. RRSP and spousal RRSP maximized. HoldCo and s.85(1) rollover shifted rental income from 50.4% personal to 27% corporate rate. Full estate plan in place.

RRSP OptimizationRESP / CESGs.85(1) RolloverHoldCoEstate PlanWills & POA
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Tax Architecture05

~$136K

Annual Tax Saving

Your 9% Corporate Rate Is Working. Your Extraction Strategy Is Not.

The Challenge

Manitoba physician earning $429K through a medical corporation. The 9% SBD rate was working — the extraction strategy was not. No HoldCo, no IPP, spouse earning $0. Every retained dollar extracted at 50.4% with no deferral engine.

The Outcome

Four levers deployed: IPP ($45K/year + $150K–$250K past service), spousal employment with TOSI exclusion ($60K salary), HoldCo intercorporate dividend engine, and COLI for AAII protection. Annual saving: $136K.

IPPSpousal EmploymentHoldCoCOLIIncome SplittingSBD Protection
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All case studies are presented anonymously. Client identities, industries, and specific figures are withheld or modified to protect confidentiality.

Your Situation

Every Structure Starts with a Diagnostic

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