Dates and location
Pricing
Hours
Dates and location
Pricing
Hours
Description
Your client’s business and personal situation is constantly changing. The existing business structure may no longer be suitable or ideal, and you are seeking tax-efficient alternatives. This course highlights fundamental income tax considerations that arise in corporate reorganizations, including a discussion of related provisions and key pitfalls to avoid.
Under the Income Tax Act (ITA), several corporate reorganization alternatives contain complex provisions that often interact with related or anti-avoidance provisions. There are a number of corporate reorganization alternatives that can be implemented under the ITA. Some of the provisions are complex and often interact with related provisions or anti-avoidance provisions. It is common for the shares and debt of corporates to be transferred between taxpayers and entities for both tax and non-tax reasons.
This course provides participants with a summary of the tools available to effect these transfers or mergers in a tax efficient manner. This course also considers the traps and anti-avoidance rules to consider when entering into such transactions. Extensive examples are used to highlight strategies and issues associated with the process of initiating a corporate reorganization.
Topics Include:
- Tax-deferred rollovers (other than Section 85)
- Wind-ups
- Amalgamations
- Share exchanges and reorganizations
- Anti-avoidance provisions
- Divisive reorganizations
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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Key Takeaways
By the end of this course, participants should be able to:
- Identify the differences between the various share-for-share and debt-for-share reorganization provisions, and the tax consequences of each.
- Describe and apply the Canadian consequences of, and the differences between, a wind-up and an amalgamation.
- Identify the anti-avoidance rules to consider when effecting a corporate reorganization.
- Describe the mechanics and the tax consequences, of a tax deferred divisive reorganization.
Who Will Benefit
This course will provide benefits to the following groups of professionals:
- Practitioners or financial executives with limited experience in share/debt reorganizations, consolidations, wind-ups, amalgamations and the GAAR.
- Professionals involved in corporate reorganizations.
- Practitioners seeking an increased understanding of relevant Canadian income tax provisions.
Prerequisite(s)
Participants should be familiar with the existing tax rules in the ITA. In particular, participants should have a reasonable understanding of the requirements and tax consequences of Section 85 of the Income Tax Act as this is foundational for several of the modules in the course.
How to Access the Course
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To access the course on your computer 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.