Corporate Reorganizations - 2022
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
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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