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Courses/Finance/Corporate Finance

Corporate Reorganizations 2025

Navigate the complex world of corporate reorganizations in 2025. This course provides comprehensive strategies for maximizing capital gains exemptions and mitigating tax risks.

Created byAJAG Professional Developmentworkspace_premium
4.9
(222 reviews)
BeginnerUpdated Dec 4, 2025
Corporate Reorganizations 2025

What You'll Learn

check_circleUnderstand reasons for corporate reorganizations by 2025.
check_circleIdentify QSBC share tests for enhanced capital gains.
check_circleNavigate part four tax traps and connected corporations.
check_circleDistinguish related and unrelated shareholder structures.
check_circleApply butterfly rules for tax-efficient asset movement.
check_circleRecognize the impact of new 55(2) purpose tests.

About This Course

The purpose of this course is to review structures that facilitate access to the capital gains exemption with a particular emphasis on audit defense, as there has been an increase in CRA audits in this area over the last couple of years.

The course will review the basic tests for the capital gains exemption and what audit documentation needs to be kept for CRA to safeguard the compliance of these tests. Further, a review of what is a bad capital gains exemption structure vs. a good capital gains structure shall be reviewed as well as ways to convert a bad structure to a good structure.

In this course, we will explore:

  • The evolving significance of the capital gains exemption, particularly in the context of Tax on Split Income (TOSI) and passive income rules.
  • Detailed analysis of Qualified Small Business Corporation (QSBC) tests including the 50% asset test, 90% asset test, and 24-month holding period, highlighting increased CRA scrutiny and common pitfalls.
  • Various corporate freeze techniques (e.g., Section 85, Section 86, Section 51, High-Low Stock Dividends) and their applications in estate planning, income splitting, and capital gains multiplication.
  • Strategies for mitigating bad corporate structures, such as unraveling complex shareholdings and addressing cash-damming issues through strategic reorganizations.
  • In-depth examination of Part IV tax traps, including challenges in "double HoldCo" structures and the implications of recent court decisions.
  • A thorough understanding of anti-avoidance rules, particularly Section 55(2), and the critical differences between Section 55(3)(a) and Section 55(3)(b) (butterfly transactions) for related and unrelated parties.
  • Crucial considerations for HST and association traps, ensuring a holistic approach to corporate reorganization.

By the end of this course, you will be able to identify reorganization objectives, implement appropriate strategies, and effectively advise clients on the sophisticated techniques required to maximize tax efficiencies and avoid costly errors in corporate reorganizations.

This course is ideal for Public Practitioners

Your Instructors

AJAG Professional Development
AJAG Professional Development
menu_book55 courses
star8,682 reviews

AJAG Professional Development was founded in 2003 with a mission of making professional development easier and more cost-effective for Canadian accountants and other financial advisory professionals. Our comprehensive range of flexible and reasonably-priced courses, programs and seminars are delivered online and in classroom-style settings in the Greater Toronto Area (Toronto, Oakville and Markham). AJAG features a roster of highly-qualified instructors who deliver content that is pertinent, up-to-date and engaging.

Manu Kakkar
Manu Kakkar

CPA, CA, TEP, MTAX

Manu has over 20 years of experience in taxation in both domestic and international, personal and corporate taxation as well as litigation support. He runs his own independent tax practice with offices in Montreal and Toronto, serving a diverse client base which includes manufacturing, retail and distribution, construction, farming, real estate, athletes and artists, across Canada and the US. His firm acts as a counsel to over 100 professional firms in Canada and USA specializing in domestic and international reorganizations and transactions. Manu is known as one of the leading experts in Section 55 of the Act and butterfly reorganizations. He is an award winning and prolific tax writer. His Master of Taxation thesis on butterfly reorganizations won 2 awards and was published in the Canadian Tax Journal. Manu has published and presented over 250 tax articles and presentations since 2001 across Canada. Manu is an authority in taxation as his name has been cited 29 times in the Income Tax Act. Manu has taught tax at The Canadian Institute of Chartered Professional Accountants, The Canadian Tax Foundation and The Society of Trust and Estate Practitioners, of and various provincial accounting bodies across Canada. He sits on the Steering Committees for the Canadian Institute of Chartered Professional Accountants’ National Conference on Income Taxes; the Canadian Tax Foundation Laval Program Committee; CPA Canada’s Small and Medium Practitioner’s Tax Committee; and the Canadian Tax Foundation’s Ontario Tax Conference. Manu is currently serving a three-year term on the Canadian Tax Foundation’s Board of Governors.

Boris  Volfovsky
Boris Volfovsky

Partner at CPA Solutions LLP

Boris has over 17 years of experience in public practice. Before becoming a partner at CPA Solutions LLP, Boris worked as a senior tax manager in the private enterprise group at one of the big four national firms. Boris has vast experience working with owner-managers and their small, medium, and large private corporations across industries. In addition, Boris is also involved in the tax community through the facilitation of the In-Depth Tax Courses, facilitation of Tax Week under the former School of Accountancy and through presenting on various tax topics at YDCPAA, PD Consortium, and AJAG.

Credit Information

Do these courses count toward my professional development requirements?

This portal is provided as a training and development resource for City of Markham employees. Every course is delivered by a qualified subject matter expert or learning organization, is quantifiable in hours, and is verifiable — you receive a documented certificate of completion for every course you finish, stored on LearnFormula indefinitely.

If you hold a professional designation (for example in engineering, accounting, human resources, or law), courses may be counted as professionally relevant, verifiable learning activities toward your continuing professional development. Individual practitioners are responsible for confirming that an activity meets the requirements of their professional body. For questions about the City of Markham's training and development policies, please speak with your people leader or Human Resources.

What Students Are Saying

4.9
Student's Choice
222 reviews

Frequently Asked Questions

We are a registered provider with 327+ associations and regulatory bodies worldwide. We operate across 29 global markets including Canada, the US, Australia, and the UK. Every course page clearly displays its specific accreditations. Upon completion, you receive a professional certificate that can be validated online. Our certificates include all necessary accreditation details, credit hours, and completion dates, and are formatted specifically to meet the submission requirements of most global regulatory bodies.