360 Degrees Wealth Strategies & Solutions Inc

06/04/2026

Double post today for

06/04/2026

Most Canadians understand that tax evasion is illegal. But fewer understand that a transaction can be 𝘵𝘦𝘤𝘩𝘯𝘪𝘤𝘢𝘭𝘭𝘺 legal and still be challenged under Canada’s General Anti-Avoidance Rule, commonly known as .

GAAR is not aimed at ordinary tax planning - Canadians are entitled to arrange their affairs in a tax-efficient way. But where a transaction produces a tax benefit through misuse or abuse of the Income Tax Act, Canada Revenue Agency - Agence du revenu du Canada may reassess the transaction and deny the benefit, plus apply the penalties under these rules.

Simply put, GAAR asks:
Did the transaction undertaken by the taxpayer merely follow the words of the law, or did it defeat the object, spirit, and purpose of the law?

A plan may technically fit inside the black-letter wording of a provision, but still be vulnerable to GAAR exposure if it exploits the Act in a way Parliament did not intend. This is especially relevant in complex planning involving corporate reorganizations, estate freezes, trust planning, shareholder transactions, and other tax-motivated structures.

The GAAR rules have also become much broader in recent years under changes to legislation. Bill C-59 received Royal Assent in June 2024, and was applicable to any transactions from January 1, 2024.

The amendments lowered the threshold of what transactions may be captured under GAAR. from a “primary purpose” test to a “one of the main purposes” test. Prior to 2024, if the “primary purpose” of a transaction was to confer a tax benefit, then that transaction could be captured under GAAR. With the updated wording in ss. 245(3), if “one of the main purposes” conferred a tax benefit, the transaction would be reviewed under these provisions.

A significant “lack of economic substance” can also be an important factor. For example, if the taxpayer’s real economic position has not meaningfully changed, but the tax result has improved, that may raise a red flag. A lack of economic substance does not automatically make a transaction abusive, but it may weigh against the taxpayer in the misuse-or-abuse analysis.

That does not mean every tax-motivated transaction is abusive, but it should make taxpayers engage with tax and legal advice where their actions may increase exposure to these broader definitions.

It’s not enough to say that, “the wording technically allows it.” But as the definitions have broadened, so should advice be broader to include whether or not a plan withstands scrutiny if reviewed with GAAR in mind - especially if the transaction is later reassessed, challenged, or tested in court.

This is why complex tax and financial planning should not be treated as a DIY exercise.

For business owners, incorporated professionals, and high-net-worth families, the issue is not simply whether a strategy reduces tax. The issue is whether the structure is legally coherent, commercially defensible, properly documented, and aligned with the purpose of the law.

Tax planning should be thoughtful, and aggressive planning brings with it a series of serious consequences.

*not tax, legal or financial planning advice. Seek qualified and certified professionals before contemplating any transaction.

06/03/2026

Most political scandals do not begin with an envelope of cash. More often, they begin when
society forgets the difference between legal compliance and public accountability.

This video examines Canada’s blind trust problem through the case of Mark Carney , his
disclosed financial interests, the Act, ethics screens, broad-class exclusions, and the larger question of whether Canada’s current accountability system is strong enough for the power concentrated in the Prime Minister’s Office.

This is not a claim that Carney broke the law. In fact, the deeper issue may be more serious:
what if the rules worked exactly as written — and still 𝘸𝘦𝘳𝘦 𝘯𝘰𝘵 𝘦𝘯𝘰𝘶𝘨𝘩?

Most political scandals do not begin with an envelope of cash. More...

06/02/2026

One of the questions Ludwig Von Mises answered in his writings was how people were attracted to as an economic model.

One of the reasons was that it made it easier to look outward rather than inward when confronting our own failures.

described the impulse to avoid thinking about our internal failures as refusing to ascribe failure to “one’s own inability,” - and instead blaming “the defectiveness of the social order” (𝘓𝘪𝘣𝘦𝘳𝘢𝘭𝘪𝘴𝘮, p. 16).

Seeking to blame a third-party becomes a kind of psychological evasion: a revolt against reason, evidence and personal accountability. Instead of examining the attitudes, skills, habits, and courage that one has not yet developed, such people find it much easier to explain their failures by blaming 𝘴𝘰𝘮𝘦𝘰𝘯𝘦 else or 𝘴𝘰𝘮𝘦𝘵𝘩𝘪𝘯𝘨 else for their condition.

They become victims of abstract circumstance. These circumstances demand political powers get involved to change and equalize outcomes.

Looking inward is harder. It requires humility, discipline, and change. But to suggest that someone you have never met is responsible for your mistakes is factually indefensible.

Once accountability is avoided, self-respect begins to erode. The individual preserves their pride by blaming society, then finds comfort among others who have made the same bargain.

Grievance becomes identity and a community is built around shared resentment. Socialism becomes the antidepressant, prescribed in “liberal” doses to sure feelings of inadequacy and failure. And eventually, something directly correlated to a personal failure becomes a political demand to reorder society.

That is the sophistry behind the appeal of : private inadequacy laundered into public grievance, wrapped in the promise that everyone’s needs can be met if only enough power is handed to the state and its actors.

Mises Institute

06/01/2026

05/31/2026

Apparently I didn’t get the memo that we weren’t doing the GQ pose and that we were actually smiling!

Had a great time in Kelowna co-presenting at Frind Estate Winery on the topic of Advanced Tax & Corporate Planning with Chris Thompson to a group of CPA tax advisors and business owners at the invitation of WealthGuard LifeSolutions last week.

05/28/2026

Sometimes deferring tax 𝘵𝘰𝘥𝘢𝘺 creates a bigger problem 𝘵𝘰𝘮𝘰𝘳𝘳𝘰𝘸.

Tax planning should never be judged only by the immediate tax savings. The better question is:
What is the 𝘁𝗼𝘁𝗮𝗹 cost?

Upfront tax matters; deferred tax matters. So do liquidity, legal structure, family control, estate risk, creditor exposure, business succession, and flexibility.

Too many Canadians become so focused on reducing tax that they forget the planning decision still has to work in real life.

I get it - taxes suck.

But the lowest tax option is not always the best planning option.

A good strategy should reduce unnecessary tax without creating larger financial, legal, or family problems later.

matters. But just like and , it shouldn’t be the 𝘸𝘩𝘰𝘭𝘦 plan.

IMO that’s why people are better served when , and professionals work together to manage client objectives with the tools at each of their disposal.

05/28/2026

Most business owners spend years focused on building value. Fewer take the time to understand what actually happens to that value when it needs to move.

Not in theory. In practice.

Because once a business becomes successful—when there are retained earnings, multiple corporations, and real wealth inside the structure—the problem changes.

It’s no longer just about growth.
It’s about:
• where liquidity comes from at the moment it’s needed
• how tax is triggered across the structure
• and whether the system you’ve built actually holds up under pressure

Most business owners spend years focused on building value. Fewer take the time to understand what actually happens to that value when it needs to move.Not i...

05/21/2026

This week’s video focuses on more and personal growth than economics or politics.
(Refreshing to some I’m sure!)

Most people think they struggle with making decisions. But often, the real struggle is not confusion. It is responsibility to understand consequences.

Most people think they struggle with making decisions.But often, the real struggle is not confusion. It is responsibility. We usually know more than we admit...

05/16/2026

“Once the king is established, the government of the kingdom must be so arranged that opportunity to tyrannize is removed. At the same time his power should be so tempered that he cannot easily fall into tyranny.”

- St. Thomas Aquinas, 𝘋𝘦 𝘙𝘦𝘨𝘯𝘰 c. 1265-1267

“A kingdom could be so instituted as that a king may not be at liberty to tyrannize over his people which only comes to pass when the sovereign power is restrained by political laws”

- Sir John Fortescue, 𝘋𝘦 𝘓𝘢𝘶𝘥𝘪𝘣𝘶𝘴 𝘓𝘦𝘨𝘶𝘮 𝘈𝘯𝘨𝘭𝘪𝘢𝘦 c. 1470, citing Aquinas

Governments need restraining, lest they grow beyond mere administrative matters. Without setting boundaries on the expansion of state and its powers, power tends to concentrate and starts increasing interference in the affairs of business, the economy, private lives of citizens, and other matters.

In their book, 𝘉𝘰𝘶𝘯𝘥𝘢𝘳𝘪𝘦𝘴, clinical psychologists Henry Cloud and John Townsend wrote that boundaries define “what is me and what is not me.” That principle does not only apply to families, marriages, and workplaces. It applies to politics.

In personal relationships, the person without boundaries says:
“Your crisis is automatically my responsibility.”

In politics, the citizen without boundaries is trained to say:
“Every social problem is automatically the government’s responsibility — and therefore automatically my tax burden, my debt burden, my inflation burden, and my loss of freedom.”

A free society requires boundaries around government for the same reason a healthy person requires boundaries around relationships.

When government has no boundaries, the citizen does not merely pay taxes. They become the emotional, financial, and moral shock absorber for a state that refuses to govern itself. Whatever the crisis, the citizens end up bearing the full cost of the burden.

The objection is not that suffering resulting from these crises does not matter, but rather there is no boundary anymore between the legitimate role of government and the private life, labour, property, conscience, and future of the citizen.

The state has become the person in the relationship who never accepts responsibility for its own behaviour, never limits its demands, and treats every “no” as moral failure.

A government without boundaries does not remain compassionate - becomes 𝗰𝗼𝗻𝘀𝘂𝗺𝗶𝗻𝗴.

It stops asking, “What are we morally permitted to do?” and starts asking, “What can we justify by declaring a need?”

Aquinas makes the same point in political language. He is not merely saying, “choose good rulers.” He is saying that even rulers must be placed inside a framework that removes the opportunity to become tyrants.

That is the essence of political boundaries.

A person without boundaries becomes vulnerable to manipulation. A government without boundaries becomes what Hobbes famously called the Leviathan: an overwhelming sovereign power justified in the name of order, security, and necessity. Not overnight, but by democratic procedure; by first reinterpreting laws that restrain the state, then by introducing new laws to exempt itself from such boundaries.

Character matters, but 𝘴𝘵𝘳𝘶𝘤𝘵𝘶𝘳𝘦 𝘮𝘢𝘵𝘵𝘦𝘳𝘴 𝘮𝘰𝘳𝘦.

A virtuous ruler may respect limits voluntarily but a corrupt ruler must be restrained by law. Because these restraints must apply objectively to an office and not subjectively to a person, they apply regardless of the political ideology of the person holding the seat of power.

Aquinas warned us over 750 years ago:

Government, rules and order may be necessary, but that necessity does not erase the need for boundaries, limitations and restrictions on power.

Because once the sovereign power is no longer restrained by law, the citizen is no longer merely governed, but rather managed, harvested and ruled.