Corporate Tax Planning - Corporate Reorganizations

Overview:

This course provides a refresher on corporate tax reorganization for private corporations. You will gain an overview of common reorganization provisions, including share exchanges, amalgamations, and windups, along with key concepts such as paid-up capital and anti-avoidance rules.

Note: This course was previously a part of Corporate Tax – Review of Tax Planning.

Course Content:

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

• Reorganization provisions:
  
  • Section 86 Reorganization of Capital
  • Section 51 Convertible Properties
  • Section 87 Amalgamations
  • Subsection 88(1) Non-taxable Winding-up
  • Subsection 88(2) Taxable Winding-up
  • Section 85.1 Share-for-Share Exchanges
  • Section 86.1 Foreign Spin-off
• Related testamentary planning tax planning touchpoints.

NOTE: this course does not cover the preparation of corporate tax returns.

Learning Objectives:

Upon completing this course, you should be able to:

• Explain the purpose and application of common reorganization provisions including the use of section 86 reorganizations, amalgamations and windup of corporations

Who Will Benefit: 

• Practitioners focused on private‑company corporate tax who want a structured, practice‑oriented review.
• Professionals seeking to refresh core planning concepts across reorganizations, transactions, and owner‑manager matters.