IV.Holdco Memorandum — A Reading
IV.
The worktable · pp. 31–46

Three instruments. One worktable.

Modest in ambition, transparent in arithmetic. Move the figures, watch the lines change. Treat the outputs as guides, not as advice.

§ 4.1

Structure Recommender.

Six short questions. The recommendation that follows is illustrative — a starting point for a conversation with your accountant.

01

What kind of business or practice do you operate?

02

Are you regularly leaving meaningful surplus inside the corporation each year?

Surplus = profit you do not need to live on, that piles up as cash or short-term investments.

03

How exposed is your operating entity to lawsuits, contracts, or operational risk?

04

What is your time horizon to drawing on this wealth?

05

Do you intend to leave wealth to a spouse or next generation?

06

Is a sale of the operating business plausible in the next 10 years?

0 of 6 answered
§ 4.2

Tax Deferral Calculator.

One year of profit, invested for a horizon, at one growth rate. Compares: paid out personally now, vs retained corporately and drawn later.

Note The corporate line assumes the surplus stays inside the corporation throughout. The “net” line subtracts the eventual personal tax when the funds are drawn.

$150,000
Profit before tax
20 years
Until you draw on the funds
6.0%
Pre-tax growth assumption
53%
Marginal rate on income drawn personally now
12%
Small-business / SBD rate
35%
When the corporation pays you in retirement
After 20 y, personal route
$226k
Already taxed; no further tax
After 20 y, corporate route — gross
$423k
Inside the Holdco
Corporate route — net of eventual draw
$275k
+$49k vs personal
y0y1y2y3y4y5y6y7y8y9y10y11y12y13y14y15y16y17y18y19y20$0$150k$300k$450k$600k
  • Personal route (taxed now)
  • Corporate route — gross
  • Corporate — net of eventual draw

Gross deferral edge after 20 years: $197,239. Net of eventual personal tax: $49,069.

§ 4.3

Insurance vs. Corporate Investing.

Compares paying the same annual amount into a corporate taxable investment account against paying it as premium into an exempt permanent life policy held by the Holdco.

Caveat The death benefit is illustrative; real policies have non-linear DB growth tied to the policy fund. Use this for shape, not for pricing.

$25,000
Premium / annual investment
25 y
Number of annual payments
6.0%
Before tax / charges
50%
Refundable + non-refundable, illustrative
1.00%
MERs, COI, surrender
15 y
Simplified — ACB drops to zero over 15 yrs after
Corp taxable a/c, y25
$911k
After passive-tax drag
Policy cash value, y25
$1.2M
Inside the Holdco-owned policy
Death benefit, y25
$1.5M
Illustrative
CDA credit on death, y25
$1.3M
Pays out tax-free
y1y2y3y4y5y6y7y8y9y10y11y12y13y14y15y16y17y18y19y20y21y22y23y24y25$0$300k$600k$900k$1.2M
  • Policy cash value
  • Corporate taxable a/c
  • Cash value inside the Holdco-owned policy compounds without annual passive-income tax.
  • The death benefit, less ACB, credits the Capital Dividend Account — paid out tax-free.
  • Premium is paid with corporate dollars, far cheaper than after-tax personal income.
  • Policy charges and surrender penalties matter; insurance is not a liquid investment.

A note on use. These instruments compress complex tax codes into a small set of inputs. They assume Canadian-style corporate / personal rates by default, ignore some attribution and integration nuances (notably the refundable tax on passive corporate investment income, and TOSI), and use simple compound growth without re-investing dividends. They are designed to teach the shape of the answer, not to produce one. Confirm any decision with a qualified accountant, tax lawyer, or insurance professional in your jurisdiction.