Pre-sale Planning

This course will cover:

1. Pre-Close Dividends and Part IV Tax Trap:

• Intercorporate dividends paid through a family trust in the year of close are potentially subject to part IV tax, even if the two companies are connected at the time of payment.
• Identifying situations that contain this trap and potential work around strategies

2. Sale of a Business in Conjunction with Bill C-208

• Discussion of Bill C-208 and how it impacts section 55
• Unresolved issues with the wording of Bill C-208
• Practical applications of Bill C-208

3. Related Party Butterfly

• Use of a Related Party Butterfly under 55(3)(a)
• Identifying situations where a 55(3)(a) butterfly would not work and potential work around strategies

Speaker(s): 

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