Share Exchanges (Section 51, 85.1, 86 and 86.1)

(Updated slides and new Recordings)

Presented by the Taxation Law Section
Co-Chairs:  Brian R. Carr, Thorsteinssons LLP | Ed Kroft, Q.C., Bennett Jones LLP

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Share Exchanges (Section 51, 85.1, 86 and 86.1)

This portion of the Tax Law for Lawyers course deals with various debt exchange and share exchange rollover provisions, including sections 51, 86, 85.1 and 86.1. Also discussed is the use of various price adjustment clauses, consideration adjustment clauses, and elected amount adjustment clauses. The equitable remedies of rectification and rescission are dealt with, including recent jurisprudence which severely narrows the scope of the rectification and rescission remedies.

Speaker

Don Cherniawsky, Q.C., Felesky Flynn LLP