Seminar on Demand – The Income Tax Act: Section 86 in Practice

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Presenter: Matt Sharp

This presentation discusses 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. It identifies how section 86 differs from section 51, notes certain issues and situations to watch for, discusses the implications of the tax on split income (TOSI) regime, outlines considerations when working with accountant, shares best practices to implement in anticipation of Canada Revenue Agency review of section 86 transactions, and summarizes post-transaction issues and opportunities.

A standard share exchange agreement is also provided.

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


Each presentation sold separately.


Please enter the first name, last name, and email of the person who will be viewing the Seminar on Demand in the billing details section on the next page.

If multiple lawyers or staff members in your firm would like to access this on-demand program (recorded from a past in-person program), please contact [email protected] for pricing.

Please note: The views and opinions of the presenters are their own and do not necessarily reflect the views or opinions of the Legal Education Society of Alberta.