Re: Canadian Amalgamation Questions.

From
Michael Jichetti <michael.jichetti@thekey.com>
To
Tammi Franzese <tammi.franzese@thekey.com>, "Rubinstein, Brian" <brubinstein@kpmg.ca>, "Johanson, Austin" <ajohanson@kpmg.ca>
CC
Timothy Thomas <tt@thekey.com>
Date
2025-09-08 15:49:38
Folder
INBOX
Adding in Austin and Brian. Is this something KPMG can help with? Thank you

On Mon, Sep 8, 2025 at 3:47 PM Tammi Franzese <tammi.franzese@thekey.com>
wrote:

> Hi Michael,
>
> Teio informed me -
>
>
>
> We do not have the CRA number for LiveWell. The business number is
> *704609759* RC0001. This number can be used to apply for the applicable
> CRA account numbers, if that hasn’t already been done.
>
> Teio suggested I connect with Tim and KPMG to get the CRA set up. I've
> copied Tim on this email. Is this something you can work with KPMG and Tim
> on?
>
> Sincerely,
>
> Tammi Franzese
>
> Senior Corporate Paralegal | TheKey
>
> Mobile: 813.521.5269
>
> <http://www.thekey.com>
>
>
>
> On Mon, Sep 8, 2025 at 3:38 PM Tammi Franzese <tammi.franzese@thekey.com>
> wrote:
>
>> Hi Michael,
>>
>> Sorry for the delay.  I followed up with CAD counsel to get the CRA
>> number. Unfortunately, we don't have a minute book with the details I
>> provided.
>>
>> Sincerely,
>>
>> Tammi Franzese
>>
>> Senior Corporate Paralegal | TheKey
>>
>> Mobile: 813.521.5269
>>
>> <http://www.thekey.com>
>>
>>
>>
>> On Thu, Aug 28, 2025 at 11:42 AM Michael Jichetti <
>> michael.jichetti@thekey.com> wrote:
>>
>>> Hi
>>>
>>> Hope all is well. I don't see an attachment. Thank you
>>>
>>> On Wed, Aug 27, 2025 at 5:03 PM Tammi Franzese <
>>> tammi.franzese@thekey.com> wrote:
>>>
>>>> Hi Michael,
>>>>
>>>> Here is the info you requested -
>>>>
>>>>  Would you happen to have the minute book detailing the company's
>>>> address, directors, share capital, and CRA account number registration
>>>> details. Also they just want to confirm the amalgamation is going to
>>>> happen Jan 1st. If anytime before that time even 11PM the night before we
>>>> will have tax consequences. Thank you, appreciate your help.
>>>>
>>>> LiveWell Care Management Inc.
>>>> 800-885 West Georgia Street
>>>> Vancouver, BC V6C 3H1
>>>> Directors: Tim Thomas, Melissa Reyes
>>>> Share capital:  HCA Home Care Assistance Canada Inc. - 100 common shares
>>>> CRA number - I'm obtaining this now. Will send it as soon as I get it.
>>>>
>>>>
>>>>
>>>> Sincerely,
>>>>
>>>> Tammi Franzese
>>>>
>>>> Senior Corporate Paralegal | TheKey
>>>>
>>>> Mobile: 813.521.5269
>>>>
>>>> <http://www.thekey.com>
>>>>
>>>>
>>>>
>>>> On Fri, Aug 22, 2025 at 2:39 PM Michael Jichetti <
>>>> michael.jichetti@thekey.com> wrote:
>>>>
>>>>> Hi
>>>>>
>>>>> I just need it for the livewell canadian entity. We have to file a NIL
>>>>> return even though they have no activity we still need to file
>>>>> unfortunately. Thank you
>>>>>
>>>>> On Fri, Aug 22, 2025 at 2:07 PM Tammi Franzese <
>>>>> tammi.franzese@thekey.com> wrote:
>>>>>
>>>>>> Hi Michael,
>>>>>>
>>>>>> I have that information for the entities. Will you please clarify
>>>>>> which entity's you are referring to?
>>>>>>
>>>>>>
>>>>>> Sincerely,
>>>>>>
>>>>>> Tammi Franzese
>>>>>>
>>>>>> Senior Corporate Paralegal | TheKey
>>>>>>
>>>>>> Mobile: 813.521.5269
>>>>>>
>>>>>> <http://www.thekey.com>
>>>>>>
>>>>>>
>>>>>>
>>>>>> On Fri, Aug 22, 2025 at 11:36 AM Michael Jichetti <
>>>>>> michael.jichetti@thekey.com> wrote:
>>>>>>
>>>>>>> Hi
>>>>>>>
>>>>>>> I spoke with my Canadian team. We need to file a return. Would you
>>>>>>> happen to have the minute book detailing the company's address,
>>>>>>> directors, share capital, and CRA account number registration details. Also
>>>>>>> they just want to confirm the amalgamation is going to happen Jan 1st. If
>>>>>>> anytime before that time even 11PM the night before we will have tax
>>>>>>> consequences. Thank you, appreciate your help.
>>>>>>>
>>>>>>> On Thu, Aug 21, 2025 at 5:20 PM Michael Jichetti <
>>>>>>> michael.jichetti@thekey.com> wrote:
>>>>>>>
>>>>>>>> Perfect thank you 😃
>>>>>>>>
>>>>>>>> On Thu, Aug 21, 2025 at 4:30 PM Tammi Franzese <
>>>>>>>> tammi.franzese@thekey.com> wrote:
>>>>>>>>
>>>>>>>>> Hi Michael,
>>>>>>>>>
>>>>>>>>> Glad to help. See answers below -
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>    1. Teio mentioned Dec 31 as the amalgamation date, but it is
>>>>>>>>>    standard practice for Canadian amalgamations to be effective January 1 so
>>>>>>>>>    that the tax years are aligned with the regular fiscal period. Has this
>>>>>>>>>    been considered?
>>>>>>>>>    1. A December 31 effective date may require an additional
>>>>>>>>>       1-day tax return which we typically want to avoid unless it is necessary
>>>>>>>>>       for another reason. - News to me, I was under the
>>>>>>>>>       impression from everything I heard it was Jan 1.* It is
>>>>>>>>>       Jan. 1, 2026*
>>>>>>>>>       2.
>>>>>>>>>
>>>>>>>>>       I think we're all saying the same thing; it's just
>>>>>>>>>       semantics. The first day of the amalgamated entity, TheKey Care Ltd.,  will
>>>>>>>>>       be Jan. 1, 2026. The amalgamation will be finalized on  12/31//2025. I can
>>>>>>>>>       obtain additional information to confirm that the business will not be
>>>>>>>>>       "active" on 12/31/25 so there would be no need for a 1-day tax return. Let
>>>>>>>>>       me know if you want me to do this.
>>>>>>>>>
>>>>>>>>>       2.
>>>>>>>>>
>>>>>>>>>    We are not familiar with the entity *LiveWell Care Management,
>>>>>>>>>    Inc.* mentioned by Teio below. Is that a new entity acquired
>>>>>>>>>    in 2025 or possibly an alternate name for one of the Canadian entities for
>>>>>>>>>    which we file tax returns? -this is the new entity created for
>>>>>>>>>    the Canadian Amalgamation. *NO*.
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>    - LiveWell Care Management, Inc. is a new entity we created in
>>>>>>>>>          2024 as a federal Canadian entity. Nina directed the creation of this
>>>>>>>>>          entity in Canada as we were also working on LiveWell in the USA. We merged
>>>>>>>>>          the CGM entities into LiveWell and changed the name of ElderCare Specialist
>>>>>>>>>          of CA  to LiveWell Care Management, LLC. LiveWell (CAD) will provide the
>>>>>>>>>          same services as in the USA.
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>    1. Can you confirm your preference for the Amalgamated entity
>>>>>>>>>    to keep the CRA business number of Orofresh further to Teio's
>>>>>>>>>    comment? We will draft a letter to CRA to communicate this once the
>>>>>>>>>    amalgamation has been actioned. - I was under the impression
>>>>>>>>>    from everything I heard we were keeping the Orofresh CRA number.
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>    - You're correct. Teio suggested we use Orofreh's CRA number
>>>>>>>>>          and we agreed. He's moving forward with that understanding and so is
>>>>>>>>>          Germaine and Ceridian.
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>    1. Can you provide some background on why it was resolved not
>>>>>>>>>    to amalgamate Arya Health Living Oakville, Inc. and LiveWell Care
>>>>>>>>>    Management, Inc.? - Don't remember off the top of my head but
>>>>>>>>>    I believe it had to do with business needs but I can find out.
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>    - Ayra (Oakville) was not included due to the staffing
>>>>>>>>>          business and wage regulations. (Tim Thomas can provide more detail if
>>>>>>>>>          needed.)
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> Sincerely,
>>>>>>>>>
>>>>>>>>> Tammi Franzese
>>>>>>>>>
>>>>>>>>> Senior Corporate Paralegal | TheKey
>>>>>>>>>
>>>>>>>>> Mobile: 813.521.5269
>>>>>>>>>
>>>>>>>>> <http://www.thekey.com>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> On Thu, Aug 21, 2025 at 3:57 PM Michael Jichetti <
>>>>>>>>> michael.jichetti@thekey.com> wrote:
>>>>>>>>>
>>>>>>>>>> Hi
>>>>>>>>>>
>>>>>>>>>> Hope all is well. I was wondering if you can confirm my answers
>>>>>>>>>> below. Appreciate your help. Thank you
>>>>>>>>>>
>>>>>>>>>>
>>>>>>>>>>
>>>>>>>>>>    1. Teio mentioned Dec 31 as the amalgamation date, but it is
>>>>>>>>>>    standard practice for Canadian amalgamations to be effective January 1 so
>>>>>>>>>>    that the tax years are aligned with the regular fiscal period. Has this
>>>>>>>>>>    been considered?
>>>>>>>>>>    1. A December 31 effective date may require an additional
>>>>>>>>>>       1-day tax return which we typically want to avoid unless it is necessary
>>>>>>>>>>       for another reason. - News to me, I was under the
>>>>>>>>>>       impression from everything I heard it was Jan 1.
>>>>>>>>>>       2.
>>>>>>>>>>
>>>>>>>>>>    We are not familiar with the entity *LiveWell Care
>>>>>>>>>>    Management, Inc.* mentioned by Teio below. Is that a new
>>>>>>>>>>    entity acquired in 2025 or possibly an alternate name for one of the
>>>>>>>>>>    Canadian entities for which we file tax returns? -this is the
>>>>>>>>>>    new entity created for the Canadian Amalgamation.
>>>>>>>>>>    3. Can you confirm your preference for the Amalgamated entity
>>>>>>>>>>    to keep the CRA business number of Orofresh further to Teio's
>>>>>>>>>>    comment? We will draft a letter to CRA to communicate this once the
>>>>>>>>>>    amalgamation has been actioned. - I was under the impression
>>>>>>>>>>    from everything I heard we were keeping the Orofresh CRA number.
>>>>>>>>>>    4. Can you provide some background on why it was resolved not
>>>>>>>>>>    to amalgamate Arya Health Living Oakville, Inc. and LiveWell Care
>>>>>>>>>>    Management, Inc.? - Don't remember off the top of my head but
>>>>>>>>>>    I believe it had to do with business needs but I can find out.
>>>>>>>>>>
>>>>>>>>>>
>>>>>>>>>> --
>>>>>>>>>>
>>>>>>>>>> *Michael Jichetti*
>>>>>>>>>>
>>>>>>>>>> Head of Tax
>>>>>>>>>>
>>>>>>>>>> Email: Michael.Jichetti@thekey.com
>>>>>>>>>>
>>>>>>>>>>
>>>>>>>>>>
>>>>>>>>>> [image: TheKey] <https://homecareassistance.com/>
>>>>>>>>>>
>>>>>>>>>
>>>>>>>>
>>>>>>>> --
>>>>>>>>
>>>>>>>> *Michael Jichetti*
>>>>>>>>
>>>>>>>> Head of Tax
>>>>

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