Corporate Restructuring – Fundamentals

Overview: 

The need for entities to continually restructure represents a present reality in the modern business landscape, including the fields of accounting and tax. Your client’s business and personal situation is constantly changing. The existing business structure may no longer be suitable or ideal, and you are seeking tax-efficient alternatives. This full-day course highlights fundamental income tax considerations that arise in corporate reorganizations, including a discussion of related provisions and key pitfalls to avoid.

Under the Income Tax Act (ITA), several corporate reorganization alternatives contain complex provisions that often interact with related or anti-avoidance provisions. There are a number of corporate reorganization alternatives that can be implemented under the ITA. Some of the provisions are complex and often interact with related provisions or anti-avoidance provisions. It is common for the shares and debt of corporates to be transferred between taxpayers and entities for both tax and non-tax reasons.

This course provides you with a summary of the tools available to effect these transfers or mergers in a tax efficient manner. This course also considers the traps and anti-avoidance rules to consider when entering into such transactions. Extensive examples are used to highlight strategies and issues associated with the process of initiating a corporate reorganization.

Course Content:

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

• Tax-deferred rollovers (other than Section 85)
• Wind-ups
• Amalgamations
• Share exchanges and reorganizations
• Anti-avoidance provisions
• Divisive reorganizations

Learning Objectives:

Upon completing this course, you should be able to:

• Identify the differences between the various share-for-share and debt-for-share reorganization provisions, and the tax consequences of each
• Describe and apply the Canadian consequences of, and the differences between, a wind-up and an amalgamation
• Identify the anti-avoidance rules to consider when effecting a corporate reorganization
• Describe the mechanics, and the tax consequences, of a tax deferred divisive reorganization

Who Will Benefit: 

• Practitioners or financial executives with limited experience in share/debt reorganizations, consolidations, wind-ups, amalgamations and the GAAR
• Professionals involved in corporate reorganizations
• Practitioners seeking an increased understanding of relevant Canadian income tax provisions