Dates and location
Pricing
Hours
Dates and location
Pricing
Hours
Description
Your or 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, 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 Income Tax Act. 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.
Under the Income Tax Act, several corporate reorganization alternatives contain complex provisions that often interact with related or anti-avoidance provisions. These provisions commonly require that the shares and debts of corporations undergo transfer between taxpayers and entities for both tax and non-tax reasons.
This course will provide participants with a summary of the tools available to effect these transfers or mergers in a tax efficient manner. The 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: No updates or changes were made to the 2023 version of this course. If you completed the course in 2021 or 2022, please be advised the 2023 course material has not changed. If you have any questions, please contact pdevents@cpaontario.ca.
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 windup and a merger.
- Identify the anti-avoidance rules to consider when effecting a corporate reorganization.
- Have a basic understanding of the mechanics of 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; and
- 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.
How to Access The Course
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.