Discuss how section 86 of the Income Tax Act allows for the exchange of shares within the same corporation to occur on a tax-deferred basis when certain criteria are met. Identify how section 86 differs from section 51, note certain issues and situations to watch for, discuss the implications of the tax on split income (TOSI) regime, outline considerations when working with accountant, share best practices to implement in anticipation of Canada Revenue Agency review of section 86 transactions, and summarize post-transaction issues and opportunities.
A standard share exchange agreement is also provided.
This on-demand program was originally presented as an in-person program in October, 2019. Total running time is 50 minutes.
Matt Sharp, GGT Chartered Professional Accountants
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