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 full-day seminar 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.
Schedule
- December 5, 2024, 8:30 a.m. - 12:30 p.m.
- December 6, 2024, 8:30 a.m. - 12:30 p.m.
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 seminar 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
This course is a live webinar. You must attend the live course to receive verifiable CPD hours. We recommend you join five minutes prior to the scheduled starting time. To get the full experience of this interactive course, use a computer that has video and microphone capabilities.
Electronic material can be accessed one week prior to the course and should be downloaded in advance.
Registration, cancellation, withdrawal and all other CPA Ontario PD policies can be found here.
Speaker(s)
Tom Pister, B. Comm., CPA, CA, LL.B. is a CPA and tax lawyer specializing in all facets of income taxation and estate planning in the private corporation and owner/manager contexts with particular expertise in the area of corporate reorganizations. He also represents clients on a variety of tax issues involving the CRA (including voluntary disclosures, tax audits, objections etc.). He has taught tax courses through CPA Ontario and the Ontario Bar Admission Course.