Corporate Reorganizations (Nov 2023)

This 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.

• Single Holdco (for Related Shareholders)
• Double Holdco (for Unrelated Shareholders)
• Tax Advantages including income splitting, multiplication of Capital Gains Exemption through family trust, purification outlet for Capital Gains Exemption
• Implementation Steps including Related Party Butterfly 55(3)(a) and Unrelated Party Butterfly 55(3)(b)
• Tax Traps including Purification Trap for CGE, subsection 55(2), corporate attribution under section 74.4 and HST trap

Speaker(s): 

• Manu Kakkar, 
• Boris Volfovsky, Partner, CPA, CA