This course assumes the participant has the basic concepts of TOSI explained in TOSI Troubles: Part I. The entire course will be based on mini-case examples which illustrate the difficulty and practical issues in dealing with TOSI in client situations involving private corporations.
Some of the concepts discussed shall be (but not restricted to):
The Importance of tracing revenue streams for TOSI
TOSI analysis for operating companies
TOSI analysis for holding companies
TOSI analysis for estates and trusts
TOSI analysis for interest, partnership income and capital gains in practical situations
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.