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Courses/Tax/Corporate Tax *

Corporate Reorganizations

This three hour course shall focus on common corporate reorganizations in the owner/manager context.

Created byAJAG Professional Development
IntermediateUpdated Dec 6, 2022
Corporate Reorganizations

About This Course




This three-hour course shall focus on common corporate reorganizations in the owner/manager context. In particular, the seminar will describe the significant income tax advantages of two classic corporate structures, the “Single Holdco” and the “Double Holdco”. The tax traps involved in the implementation of such structures will also be discussed.

TOPICS:

  • Single Holdco (for Related Shareholders)
  • Double Holdco (for Unrelated Shareholders)

Tax Advantages:

  • Income Splitting
  • Multiplication of Capital Gains Exemption through family trust
  • Purification outlet for Capital Gains Exemption

Implementation Steps (“Breaking Up is Hard to Do”):

  • Related Party Butterfly 55(3)(a)
  • Unrelated Party Butterfly 55(3)(b)

Tax Traps:

  • Purification Trap for CGE: watch out for inter-corporate debt!
  • Subsection 55(2)
  • Corporate Attribution under section 74.4
  • HST Trap





 

Your Instructors

AJAG Professional Development
AJAG Professional Development
menu_book55 courses
star9,376 reviews

AJAG Professional Development was founded in 2003 with a mission of making professional development easier and more cost-effective for Canadian accountants and other financial advisory professionals. Our comprehensive range of flexible and reasonably-priced courses, programs and seminars are delivered online and in classroom-style settings in the Greater Toronto Area (Toronto, Oakville and Markham). AJAG features a roster of highly-qualified instructors who deliver content that is pertinent, up-to-date and engaging.

Manu Kakkar
Manu Kakkar

CPA, CA, TEP, MTAX

Manu has over 20 years of experience in taxation in both domestic and international, personal and corporate taxation as well as litigation support. He runs his own independent tax practice with offices in Montreal and Toronto, serving a diverse client base which includes manufacturing, retail and distribution, construction, farming, real estate, athletes and artists, across Canada and the US. His firm acts as a counsel to over 100 professional firms in Canada and USA specializing in domestic and international reorganizations and transactions. Manu is known as one of the leading experts in Section 55 of the Act and butterfly reorganizations. He is an award winning and prolific tax writer. His Master of Taxation thesis on butterfly reorganizations won 2 awards and was published in the Canadian Tax Journal. Manu has published and presented over 250 tax articles and presentations since 2001 across Canada. Manu is an authority in taxation as his name has been cited 29 times in the Income Tax Act. Manu has taught tax at The Canadian Institute of Chartered Professional Accountants, The Canadian Tax Foundation and The Society of Trust and Estate Practitioners, of and various provincial accounting bodies across Canada. He sits on the Steering Committees for the Canadian Institute of Chartered Professional Accountants’ National Conference on Income Taxes; the Canadian Tax Foundation Laval Program Committee; CPA Canada’s Small and Medium Practitioner’s Tax Committee; and the Canadian Tax Foundation’s Ontario Tax Conference. Manu is currently serving a three-year term on the Canadian Tax Foundation’s Board of Governors.

Credit Information

What Students Are Saying

4.5
Student's Choice
126 reviews

Frequently Asked Questions

We are a registered provider with 300+ associations and regulatory bodies worldwide. We operate across 27 global markets including Canada, the US, Australia, and the UK. Every course page clearly displays its specific accreditations. Upon completion, you receive a professional certificate that can be validated online. Our certificates include all necessary accreditation details, credit hours, and completion dates, and are formatted specifically to meet the submission requirements of most global regulatory bodies.

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