Section 85 Rollovers - 2022
The three hour course provides a fresh new look at section 85 rollovers. The seminar will begin with basic concepts such as, for example, what properties are eligible, what is the elected amount, and how to compute the paid-up capital of the consideration shares. The course shall describe the common usages for section 85, as well as various traps that may arise when the rollover is used. In particular, the course will discuss the possibility of a PUC grind under subsection 84(1), HST issues that may arise on any asset transfer, as well as the gifting provision under paragraph 85(1)(e.2). Recent developments in CRA interpretations and cases will also be discussed.
TOPICS
Basic concepts
Elected Amount
Boot
PUC of consideration shares
FMV rule
Practical Tips and Traps in Filling out the T2057
Traps to watch out for:
84(1)
85(1)(e.2)
HST
Instructor
Manu Kakkar CPA, CA, BSc(Hons), TEP, MTax & Boris Volfovsky, CPA, CA
Manu has over 20 years of experience in taxation in both domestic and international, personal and corporate taxation as well as expert witness reports and testimony.
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.
Boris has over 17 years of experience in public practice. Before becoming a partner at CPA Solutions LLP
Boris worked at one of the big four national firms as a senior tax manager in the private enterprise group.
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