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).
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.
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.
- Tax-deferred rollovers (other than Section 85)
- Share exchanges and reorganizations
- Anti-avoidance provisions
- Divisive reorganizations
Participants should be familiar with the existing tax rules in the ITA.
COURSE LEADER: FRANK LAVITT, LL.B, B.Comm (Hons)