CBA Tax Law for Lawyers Online Recordings: Reorganizations 

Jun. 1, 2021 - Mar. 31, 2022

CBA Tax Law for Lawyers Online Recordings


Presented by the Taxation Law Section
Co-Chairs:  Brian R. Carr, Thorsteinssons LLP | Ed Kroft, Q.C., Bennett Jones LLP

CBA members: $199
CBA Young Lawyer Members (<5 years): $120
CBA Student members: $49
Non-members: $429
Government: $329
Plus applicable taxes

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Total Content Time: 6.25 CPD Hours

This grouping reviews the provisions of the various sections of the Income Tax Act (Canada) (the “Act”) that allow taxpayers to carry out on a tax-deferred basis the following transactions:

  • The transfer of assets (including shares of a corporation) to another corporation for consideration including shares of the transferee corporation;
  • The exchange of debt and shares of a corporation for shares of the corporation;
  • The exchange of shares of one corporation for shares of another corporation;
  • The capital reorganization of a corporation pursuant to which a shareholder receives debt and shares of a corporation for shares of the corporation;
  • A distribution by a non-resident corporation of shares of another corporation;
  • The amalgamation of two or more corporations; and
  • The winding-up of one corporation into another.


We will also consider when distributions made by one corporation to another are not exempt from tax as well as the distribution on a tax-free basis of the assets of a corporation to one or more shareholders of the corporation.

  1. Rollovers – Section 85 
  2. Share Exchanges (Section 51, 85.1, 86 and 86.1)
  3. Amalgamations and Wind-Ups 
  4. Corporate Distributions 
  5. Divisive Reorganizations 




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