This course provides a practical approach and guidance on identifying, planning, documenting, and implementing reorganizations of private corporate groups.

Those involved with reorganizing private corporations need to consider a wide range of technical rules, develop a plan that meets the client’s objectives, navigate the practical challenges of implementing the plan, and communicate the plan to other professionals. Participants will apply this approach using mini-cases throughout the course. A brief high-level review of Income Tax Act (ITA) sections and other common technical rules will be provided, but participants should have a good working knowledge of these rules.

Topics Include:

• The collection and evaluation of client information and objectives.
• The identification of alternatives and development of a plan.
• A high-level review of key technical Income Tax Act provisions, including Section 85, QSBC rules, Section 55, Part IV tax, Stop-loss rules, and Attribution rules and TOSI.
• Loss utilization and employee buy-in.

NOTE: This course description has been revised and reflects updates for 2024. If you have any questions, please contact pdevents@cpaontario.ca.

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By the end of this course, participants should be able to:

• Identify problems with corporate structures and develop alternatives.
• Identify and analyze income tax rules that can impact the proposed transactions.
• Prepare a structured plan to implement a reorganization.