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.
Single Holdco (for Related Shareholders)
Double Holdco (for Unrelated Shareholders)
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)
Purification Trap for CGE: watch out for inter-corporate debt!
Corporate Attribution under section 74.4
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.