Reorganizations

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

COST FOR THE GROUP OF RECORDINGS 
CBA members: $199
CBA Young Lawyer Members (<5 years): $120
CBA Student members: $49
Non-members: $429
Government: $329
Plus applicable taxes

Purchase individual sessions below or the full group for the best rates.

Group rates available. Please contact pd@cba.org.

Reorganizations

Total Content Time: 6.25 CPD Hours

This grouping reviews the provisions of the various sections of the Income Tax Act (Canada) (the “Act”) that allow taxpayers to carry out on a tax-deferred basis the following transactions:

• The transfer of assets (including shares of a corporation) to another corporation for consideration including shares of the transferee corporation;
• The exchange of debt and shares of a corporation for shares of the corporation;
• The exchange of shares of one corporation for shares of another corporation;
• The capital reorganization of a corporation pursuant to which a shareholder receives debt and shares of a corporation for shares of the corporation;
• A distribution by a non-resident corporation of shares of another corporation;
• The amalgamation of two or more corporations; and
• The winding-up of one corporation into another.

We will also consider when distributions made by one corporation to another are not exempt from tax as well as the distribution on a tax-free basis of the assets of a corporation to one or more shareholders of the corporation.

1. Rollovers – Section 85 
2. Share Exchanges (Section 51, 85.1, 86 and 86.1)
3. Amalgamations and Wind-Ups 
4. Corporate Distributions 
5. Divisive Reorganizations