An Introduction to Tax-Deferred Share Exchanges and Section 51

SKU: 62137.02 Categories: , Tag:


Author: Scott McCamis

This paper has three main components. First, it discusses the purpose of a tax-deferred share exchange and introduces some fundamental concepts for planning and implementing a share exchange. Second, it contains a high-level discussion of the technical requirements and mechanics of section 51 of the Income Tax Act. Third, it reviews some practical issues that arise in planning or documenting a section 51 share exchange.

This paper also includes a set of example documents for the implementation of a basic section 51 exchange of common shares for preferred shares by an individual shareholder.

This paper is part of a collection presented at LESA’s Tax Law for Corporate/Commercial Transactions program in Calgary on October 17, 2019 and in Edmonton on October 28, 2019.

These materials are an electronic product in Adobe PDF format. Shortly after your purchase, you will receive an email with instructions on how to download the complete PDF.   

Click here to view some sample pages.

This paper is also offered as part of a Seminar on Demand. Purchasing the Seminar on Demand allows you to stream video recordings of seminar presentations and download PDF materials.