Corporate Tax Planning - Deemed Dividends & Corporate Attribution

Overview:

You will refresh and deepen your understanding of key corporate tax concepts and planning touchpoints for private corporations, with selective coverage of public‑company considerations. You will analyze current rules, anti‑avoidance provisions, and common reorganization and transaction scenarios through cases and practical examples.

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:

• Paid‑up capital
• Repurchase and Redemption of Shares
• 84(1) Deemed Dividends
• 84(4), (4.1) PUC reductions
• Section 84.1
• Intergenerational transfers
• Corporate attribution rules

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

Learning Objectives:

Upon completing this course, you should be able to:

• Understand the concept of paid-up capital and why the calculation is important for tax planning
• Understand provisions that cause unintended tax consequences depending on the paid up capital
• Know when intergenerational transfers can be applied
• The application of the corporate attribution rules

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.