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Tax Implications of Inter-company Transactions in a Closely Held Group

Individual Course Price: $175.00

Number of PD Hours: 3

Topics will include:

  • Historical treatment of intercompany fees.
  • Judicial support for intercompany fees - the Safety Boss case.
  •  The personal service business rules.
  • HST issues.
  • Comparison of the income sources previously eligible for the small business deduction and the sources now eligible.
  • Changes to the S.256(2) election to disassociate corporations.
  • Corporate partners; old rules versus new rules – non-partner corporations deemed to be partners under the new rules.
  • Assignment of entitlement to the small business deduction by a partner that pays a fee or other amount to the recipient – S.125(8).
  • Anti-avoidance rules.
  • Assignment of entitlement to the small business deduction by the payor of a fee or other amount to the recipient – S.125(3.2).
  • Exemption from the new rules where the intercompany transactions are between associated corporations – S.125(10) – and the limitations to the exemption.
  • Management companies and new rules.
Course Sessions:
CodeProgramSession DateStart Time 
102320192019/2020 Oakville Mornings (Wed) 10/23/2019 8:30 AM
Online201952019/2020 Online 10/1/2019 12:00 AM
092420192019/2020 Markham Mornings (Tues) 9/24/2019 9:00 AM
Quick Links
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In-Class locations:

Toronto - Temple Sinai. 210 Wilson Ave, North York, ON M5M 3B1


Oakville - Le Dome. 1173 North Service Road East. Oakville, L6H 1A7


Markham - Markham Event Centre. 95 Duffield Drive, Markham, L6G 0A8


How to Save Even More

For our accounting professional development programs:

 

SAVE $255 

when you register for our core package of 7 courses as opposed to buying each course individually


SAVE $440

when you register for our classic package of 11 courses as opposed to buying each course individually

 

SAVE $280

when you register for our flex package of 14 courses as opposed to buying each course individually

 

If your firm is purchasing more than 10 packages please contact Alison Winton for pricing 

(905) 881-9285 ext 102