The Rural Voice, 1990-06, Page 18GICRATES FOR 45
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14 THE RURAL VOICE
THE FUTURE OF THE FARM - PLAN AHEAD
To preserve a farm for succeeding
generations and to prevent the unnec-
essary erosion of farm values through
taxation requires planning.
Using the provisions of the In-
come Tax Act, along with creativity
in drafting a will and in developing an
estate plan, will help ensure the con-
tinuation of the family farm in accor-
dance with the wishes stated in a will.
Estate planning will depend on
a testator's circumstances. If the farm
is to go to a spouse or child alone, no
special provisions may be needed.
This simple scenario, however, is
often not the case.
If a testator wants to provide for a
spouse and several infant children, and
the farm is the bulk of the estate, it
may be best to establish a spousal trust
to hold the farm property, with a fur-
ther rollover to the children upon the
spouse's death, if still available.
If the testator expects the children
will continue the farm business, but
the surviving spouse will be unable to
operate the farm, he might provide for
the employment of a manager. Or the
property could be leased out, with the
income generated going to the trust.
If a testator wants to provide for a
spouse and several adult children, it
might be best to provide for the spouse
through life insurance and a Life in-
terest in the matrimonial home.
Alternatively, the home might be
severed prior to the testator's death
and transferred to the spouse outright
under the will. The farm property
could then be transferred to the chil-
dren jointly if all the children wish to
continue farming.
If only one of the children wants to
farm, the farm could be rolled over to
that child and life insurance could be
used to fund bequests of equal value
to the other children.
Another alternative would be to
give the child who wants to farm the
option of buying out the interests of
the other children, possibly by grant-
ing them mortgages.
The solution may be easier if the
farm is incorporated. The rollover
provisions of the Income Tax Act con-
tinue to apply (to avoid the taxation of
capital gains) and the share structure
can be arranged during a testator's
lifetime for a clean, easy disposition.
Alternatively, the children who do
not want to farm could be granted
shares which permit fixed or limited
participation in income distribution.
Profit participating shares would be
granted to the children who do farm.
One option frequently used for an
incorporated farm is known as an "es-
tate freeze." This attempts to minim-
ize capital gains tax after a death by
ensuring that the value of the taxpay-
er's estate will not increase after the
freeze is implemented.
A common method of "freezing" is
that a taxpayer "freezes" his interest in
the value of a corporation by exchang-
ing the profit -participating shares
(common shares) of a family farm cor-
poration for fixed income shares (pre-
ferred shares). The common shares
are then purchased by the children.0
Agrilaw is produced by Cohen,
Melnitzer, a full-service London law
firm. Marlene McGrath practises in the
areas of corporate and commercial law,
wills, and estate planning. Agrilaw is
intended to provide information to
farmers on subjects of interest and
importance. The opinions expressed are
not intended as legal advice. Before
acting on any information in Agrilaw,
readers should obtain legal advice with
respect to their own circumstances.