Corporate Restructuring - Fundamentals (OC)

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. This live virtual session will be delivered as a two-segment session (Feb 1 & 2, 1:00 pm - 4:30 pm each day).

OBJECTIVE:
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 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, 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. 

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.

WHO WILL BENEFIT:
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.

LEARNING OUTCOMES:
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, and
  • have a basic understanding of the mechanics of and the tax consequences of a tax deferred divisive reorganization. 

CONTENT:

  •  Tax-deferred rollovers (other than Section 85)
  • Wind-ups
  • Amalgamations
  • Share exchanges and reorganizations
  • Anti-avoidance provisions
  • Divisive reorganizations

PREREQUISITES:
Participants should be familiar with the existing tax rules in the ITA.

COURSE LEADER: FRANK LAVITT, LL.B, B.Comm (Hons)

When
2/1/2022 1:00 PM - 2/2/2022 4:30 PM
Canada Central Standard Time
Where
Online Course

Personal Passport Eligibility

Corporate Passport Eligibility

 

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