Participants will gain a practical understanding of core corporate reorganization tools under the Income Tax Act, including share-for-share and debt-for-share provisions, wind-ups, amalgamations, divisive reorganizations, and related anti-avoidance considerations. The course emphasizes how these rules interact, common traps to avoid, and the steps to plan and execute restructurings efficiently.

• Practitioners or financial executives with limited experience in share/debt reorganizations, consolidations, wind-ups, amalgamations, and GAAR who want a structured fundamentals overview. 
• Professionals involved in corporate reorganizations who seek a clearer understanding of relevant Canadian income tax provisions and common pitfalls.  

• Differentiate between key share and debt reorganization provisions and explain the tax consequences of each. 
• Describe and apply the Canadian tax consequences of wind-ups and amalgamations, including when each approach is appropriate. 
• Identify and assess relevant anti-avoidance provisions (e.g., sections 55, 84.1, GAAR) and related benefit/attribution rules in the context of reorganizations. 
• Explain the mechanics and tax implications of tax-deferred divisive reorganizations and recognize common pitfalls. 

• Share/debt reorganizations: sections 51, 51.1, 85.1, 86 (purpose, requirements, ordering, PUC, history preservation, comparisons). 
• Consolidations: amalgamations (incl. bumps and special cases) and wind-ups (requirements, results, planning considerations). 
• Anti-avoidance and related rules: sections 55 and 84.1, benefit provisions, attribution rules, special taxes, GAAR, and mandatory disclosure considerations. 
• Divisive reorganizations: paragraph 55(3)(a) related-party reorganizations and paragraph 55(3)(b) butterfly transactions (overview, property types, denial rules, and illustrative steps). 

Live webinars have varying levels of expected interaction, with some requiring microphone and camera capabilities to support a proper learning experience – please email pdreg@bccpa.ca if you have concerns. 

In general, we encourage participants to have their cameras turned on to enhance their virtual learning experience. This practice promotes a stronger connection with the instructor and fellow participants, and fosters improved communication and collaboration.

Live Webinar FAQs can be found here.  

Registration terms and conditions, including the cancellation policy can be found here. If you require further assistance, please contact the PD Department.