It is useful to take a fresh look at a corporate structure from time to time to determine whether every available tax-planning opportunity has been employed. This exercise is worthwhile every few years because circumstances and laws change, yielding new opportunities or unexpected drawbacks.

When approaching this kind of engagement, we

• meet with representatives of the corporation, or the corporation’s accountants, to review the group’s overall structure, financial statements, and tax returns;
• prepare a short report summarizing our tax-planning ideas;
• carefully consider shareholder remuneration issues and the tax issues of selling the corporation in the longer term;
• where warranted, prepare a detailed implementation memo to put our tax-planning ideas into effect; and
• monitor the structure for opportunities created by changes in tax laws or other circumstances if we are engaged to do so.