Author: Matthew Clark

It is important for lawyers advising on estate freezes, succession planning, and business restructurings to understand section 51 share exchanges. This paper explores section 51 requirements and benefits, common applications, pitfalls and red flags, and key provisions in section 51 agreement.

These materials were presented at LESA’s Tax-Deferred Share Exchanges Under Section 51: A Primer for Lawyers webinar on October 7, 2025.