RE:RE:RE:Deal by year end? As far as I know, Roger and Cynthia are still Canadian tax residents, but I gather from comments that Roger made on FB that they are exploring future move to Panama.
Of course it is not just them, but other members of the Board.
The math is tricky, and not sure if Ontario will follow suit, but when I looked at it quickly, it seemed like it was almost equivalent to increasing inclusion rate to 2/3 from in a sneaky way.
This flow from increasing inclusion rate for AMT purposes to 100% from 80% and tax rate from 16+% to 20+%.
This is not to say that there are not ways around it. As long as deal announced before year end, they can take steps to trigger accrued gain this year, even if not closed. In addition, rollover to corporation of personal holdings may also work to avoid the AMT.