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Common Corporate Reorganizations - filmed in 2016

Individual Course Price: $175.00

Number of PD Hours: 3

Course Code: OL19Common

Date: Now Available

Time: Now Available

Location: 

AJAG Online

THIS COURSE WAS FILMED IN 2016

 

This three hour course shall focus on common corporate reorganizations in the owner/manager context. In particular, the seminar will describe the significant  income tax advantages of two classic corporate structures, the “Single Holdco” and the “Double Holdco”. The tax traps involved in the implementation of such structures will also be discussed.

TOPICS

  • Single Holdco (for Related Shareholders)

  • Double Holdco (for Unrelated Shareholders)

  • Tax Advantages:

    • Income Splitting

    • Multiplication of Capital Gains Exemption through family trust

    • Purification outlet for Capital Gains Exemption

  • Implementation Steps (“Breaking Up is Hard to Do”)

    • Related Party Butterfly 55(3)(a)

    • Unrelated Party Butterfly 55(3)(b)

  • Tax Traps

    • Purification Trap for CGE: watch out for inter-corporate debt!

    • Subsection 55(2)

    • Corporate Attribution under section 74.4

    • HST Trap

 

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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


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

(905) 881-9285 ext 102