Dates and location
Pricing
Hours
Dates and location
Pricing
Hours
Description
This advanced certification is designed for CPAs who have completed or possess equivalent knowledge to CPA Ontario’s Tax Immersion Program Parts 1, 2, and/or Owner-Managed Structures program. It is intended for practitioners who are ready to move into the practical execution of tax transactions, while strengthening their tax-research and advisory capabilities.
Early Bird Sale: Save 25% on this program by registering before September 30, 2026. Promotion cannot be combined with other offers or Passport.
The certification is structured around three core pillars, each reflecting how tax advisory work is actually performed in practice.
- Learn How to Research and Interpret Tax Law
This program emphasizes how to research and interpret tax law independently. Participants will develop a repeatable research methodology that teaches them how to:- Navigate and interpret the Income Tax Act and Income Tax Regulations.
- Locate and analyze CRA administrative positions, rulings, interpretations, and folios.
- Identify, read, and apply relevant court decisions.
- Execute Transactions Using Professional Memoranda
The most distinctive feature of this certification is its focus on transaction execution. Participants will be shown how tax planning is implemented in practice, including:- How to draft step memo used to execute tax transactions including instructions to legal counsel.
- How to review the legal documents before finalizing the transaction.
- Apply Technical Knowledge Through Practical, Case-Based Execution
This certification emphasizes practical application through extensive case studies. Participants will work through realistic scenarios that require them to complete elections, forms, and filings using professional tax software. The focus is on doing the work, not just understanding the rules.
How This Program Will Be Delivered
This course uses a blended format combining instructor-led sessions with collaborative group study. Participants will learn core concepts through guided instruction and then work in small groups with other practitioners to research the Income Tax Act and related materials, applying the rules to practical case studies in a hands-on, practice-focused environment.
Prerequisites
To enroll in this program, participants must meet at least ONE (1) of the following criteria (completion of all items is NOT required):
- Have successfully completed one of the following programs: Immersion Program Part 1, Immersion Program Part 2, or the Owner-Managed Certification Program; OR
- Have more than six (6) years of tax experience and are currently employed in a role where at least 75% of their responsibilities are tax-related; OR
- Have completed the CPA In-Depth Tax Program or a Master of Taxation program.
Speak to an Advisor
To learn more about the program, please use this form to Speak to an Advisor.
Program Schedule
Module 1: Learn How to Research and Interpret Tax Law (20 hours)
Virtual on Zoom
Time: 9:00 a.m. — 10:30 a.m.
On Demand
Participants will be introduced to tax research as a systematic, five-step process (facts → issues → sources → evaluation → communication).
Module 1.2A (2 hours)
On Demand
Lecture on key personal income tax topics, including residency determination, deductibility of employment expenses, and employee versus contractor classification. This foundational knowledge is required before progressing to Module 1.2B.
Virtual on Zoom
Time: 8:30 a.m. — 12:30 p.m.
Building on the learning from Module 1.2A and using employment-income case examples, the emphasis is on how to read and research the Income Tax Act and how to locate, assess, and apply interpretive sources, including CRA views, advance rulings, and relevant court decisions.
On Demand
Lecture on business-income topics and common tax adjustments, including financing expense deductions, interest deductibility, and the treatment of legal fees related to mergers and acquisitions. This foundational knowledge is required before progressing to Module 1.3B.
Virtual on Zoom
Time: 8:30 a.m. — 12:30 p.m.
Building on the learning from Module 1.3A and business-income case examples, the emphasis is on how to read and research the Income Tax Act.
On Demand
Lecture on income and corporate attribution rules, as well as shareholder loans. This foundational knowledge is required before progressing to Module 1.4B.
Virtual on Zoom
Time: 8:30 a.m. — 12:30 p.m.
Through a focused case study, participants will practice researching the Income Tax Act to understand the application of attribution rules.
Module 2: Interpreting Inter-Corporate Dividend Rules & Anti-Avoidance Provisions (10 hours)
On Demand
In-depth Modules covering Subsection 55(2), with an emphasis on safe income identification, allocation, and computation, subsections 55(3)(a) and 55(3)(b) reorganizations.
Virtual on Zoom
Time: 8:30 a.m. — 12:00 p.m.
In-depth Modules covering Subsection 55(2), with an emphasis on safe income identification, allocation, and computation, subsections 55(3)(a) and 55(3)(b) reorganizations.
Virtual on Zoom
Time: 8:30 a.m. — 12:00 p.m.
In-depth Modules covering Subsection 55(2), with an emphasis on safe income identification, allocation, and computation, subsections 55(3)(a) and 55(3)(b) reorganizations.
Module 3: Insight Into Key International Tax Topics & Refresher of Canadian Domestic Tax Rules (14 hours)
On Demand
This module covers the core concepts of Canadian withholding taxes, income tax treaties, and transfer pricing strategies.
Module 3.2 (4 hours)
On Demand
Practical application of Canada’s inbound tax rules, including determining when a non-resident is carrying on business in Canada, identifying permanent establishment exposure, and understanding branch tax implications. Participants will learn the use of Regulation 102 and 105 waivers and RC473 filings, along with key compliance requirements for inbound companies. The lecture also addresses thin-capitalization rules, subsection 15(2) shareholder loans, management fee arrangements, etc.
Module 3.3 (3 hours)
On Demand
This module on international outbound taxation will teach participants the Canadian rules applicable to foreign affiliates and controlled foreign affiliates, with a practical focus on identifying outbound tax exposures. Participants will review the subsection 90(6) upstream loan rules, surplus dividend regimes, and section 212.1 anti-avoidance provisions, along with the computation and interpretation of FAPI, FAPL, and FAT.
Module 3.4 (2 hours)
On Demand
Emigration of a Business Owner from Canada (Deemed Dispositions and Loss of CCPC Status).
Module 3.5 (3 hours)
On Demand
This refresher session reinforces participants’ existing knowledge of tax-deferred rollovers by focusing on the practical application and execution of rollover provisions for corporations, partnerships, and trusts.
Module 4: Practical Execution of Common Corporate Reorganizations (11 hours)
Virtual on Zoom
Time: 8:00 a.m. — 12:30 p.m.
In this module, participants will work through the practical execution of an estate freeze, reviewing the various implementation approaches, including section 86, section 85(1), and stock dividend strategies. The module covers the use of a family trust, drafting a detailed steps memorandum with legal instructions, and preparing a separate steps memo for the creation of a family trust. Participants will also review the trust deed and related legal documents, and complete the relevant tax compliance forms using tax software, reinforcing the full end-to-end execution of the transaction.
Virtual on Zoom
Time: 8:00 a.m. — 12:30 p.m.
This module focuses on the practical implementation of a subsection 55(3)(a) reorganization to remove non-qualifying assets efficiently. Participants will prepare a detailed steps memorandum with instructions for legal counsel, and complete the required tax compliance using tax software, reinforcing the end-to-end execution of the strategy.
Virtual on Zoom
Time: 8:00 a.m. — 12:00 p.m.
This module examines the practical application of genuine intergenerational business transfers, focusing on how section 84.1 restricts family share sales and when the intergenerational transfer rules provide relief.
Module 5: Corporate Income Tax Returns for Aquisitions of Control and Amalgamations (15 hours)
On Demand (until January 13, 2027)
This module revisits acquisition of control and loss restriction event rules, focusing on distinguishing an acquisition of control from a change in control, including reverse takeovers. Participants will apply the rules through a hands-on case study, completing acquisition-of-control tax compliance using software to reinforce practical execution.
Module 5.2 (4 hours)
On Demand (until January 13, 2027)
This module focuses on the amalgamation rules, highlighting when an amalgamation qualifies as a tax-deferred reorganization. Participants will apply the rules through a hands-on case study, completing amalgamation-year tax compliance using software.
Module 5.3 (5 hours)
On Demand (until January 13, 2027)
This module focuses on deferred income tax provisions, with an emphasis on identifying temporary differences arising from common reorganization transactions. Participants will apply the concepts through a practical case study, preparing a deferred tax provision and linking tax compliance results to financial reporting outcomes.
Virtual on Zoom
Time: 9:00 a.m. — 11:00 a.m.
During this session, participants will have the opportunity to ask and discuss any final questions before the certification program concludes. This open forum allows participants to clarify concepts, revisit complex topics covered throughout the course, and ensure they are fully prepared as they wrap up the certification.
Earn a Digital Badge
Our new collection of digital badges can be earned through the completion of any of our certificate programs offered in our professional development catalogue. Collect these digital badges to add to your website, social profiles, email signature and more. These badges are an easy way to visually communicate your skills and accomplishments to your peers and network. Digital badges will be awarded based on course completion requirements.
Who Will Benefit
This program is for CPA and non-CPA tax professionals and advisors with an existing technical foundation who want to move beyond understanding tax rules into independent research, practical execution, and implementation.
Frequently Asked Questions
- What is the major focus of this program?
The primary focus is to help participants confidently read, navigate, and interpret the Income Tax Act (ITA), and to independently conduct tax research using CRA administrative positions, technical interpretations, and relevant court decisions.
- Some topics appear similar to those covered in previous Immersion Programs. Why are they included again, and will the learning be different?
Yes—while select topics are revisited, they are introduced at a deeper, more practical level. These topics are refreshed because they are essential foundations for the new material. Unlike prior programs that focused on understanding the rules, this program takes you further into execution by introducing step memorandums, demonstrating how transactions are implemented in practice, and showing how related compliance is completed using tax software.
- Why does the program use a group study format?
Group study is intentionally used to enhance learning, particularly when developing ITA research skills. Working in smaller groups encourages discussion, shared problem-solving, and deeper understanding as participants navigate complex legislation and research materials together.
- How is this program different from other ITA research programs?
This program uniquely integrates three components—technical research, practical execution, and compliance application—providing a comprehensive, end-to-end learning experience that goes beyond standalone ITA research courses.
Need Approval to Attend?
How to Access the Program
To access the course please visit our BlackBoard site, and log-in using the same login and password used for the Registration Portal.
Please allow up to 15 minutes after registration for the course to appear on your BlackBoard page.
Registration, cancellation, withdrawal and all other CPA Ontario PD policies can be found here.
Any pre-reading or course work to be completed prior to the program will be emailed to you in advance of the program start. Please ensure your email address is up-to-date.
Participants will have access to the on-demand materials until January 14, 2028.
There are no refunds for this program. If you have registered for this event and wish to request to defer your registration to a later date, please contact our customer service desk at pd@cpaontario.ca. Requests must be made at least 2 weeks prior to the program start date (October 30, 2026), after which, no deferrals will be considered.
Speaker(s)
Haroon Khan is an experienced tax professional, having served over 14 years at the world’s leading accounting firms, including the Big 4, as Senior Tax Manager and Tax Partner. Haroon obtained his BBA degree from U of T before qualifying as a CPA, CA in Canada and as a U.S. CPA. He has also completed all three parts of CPA Canada’s In-Depth Tax Program. Haroon is a passionate instructor. He develops and trains fellow tax professionals as an instructor with various CPA Canada educational programs, including Professional Development seminars, Professional Education, and In-Depth Tax Programs. He is also a lecturer at the Schulich School of Business, where he has taught both MBA and BBA students.