Corporate Restructuring – Application for Private Corporations

Overview:

Master the practical approach to reorganizing private corporate groups. This course provides a practical approach and guidance on identifying, planning, documenting, and implementing reorganizations of private corporate groups.

Those involved with reorganizing private corporations need to consider a wide range of technical rules, develop a plan that meets the client’s objectives, navigate the practical challenges of implementing the plan, and communicate the plan to other professionals. You will apply this approach using mini-cases throughout the course. A brief high-level review of Income Tax Act (ITA) sections and other common technical rules will be provided, but you should have a good working knowledge of these rules.

Course Content:

In this course, you will gain knowledge about the following topics:

• The collection and evaluation of client information and objectives
• The identification of alternatives and development of a plan
• A high-level review of key technical Income Tax Act provisions, including Section 85, QSBC rules, Section 55, Part IV tax, Stop-loss rules, Attribution rules and TOSI
• Loss utilization and employee buy-in

Learning Objectives: 

Upon completing this course, you should be able to:

• Identify problems with corporate structures and develop alternatives
• Identify and analyze income tax rules that can impact the proposed transactions
• Prepare a structured plan to implement a reorganization

Who Will Benefit: 

Although most tax professionals would benefit from this course, it particularly targets practitioners and managers involved in reorganizations or tax planning for groups of privately held companies.