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Courses/Business/Sales skills

Pre-sale Planning: Sales and Reorganizations of a Business

Pre-sale Planning: Selected Issues with Sales and Reorganizations of a Business.

Created byAJAG Professional Developmentworkspace_premium
4.7
(19 reviews)
BeginnerUpdated Mar 11, 2024
Pre-sale Planning: Sales and Reorganizations of a Business

What You'll Learn

check_circleUnderstand the concept of pre-close dividends and their interaction with Part IV tax.
check_circleIdentify scenarios where intercorporate dividends paid through a family trust may trigger Part IV tax implications.
check_circleAnalyze the potential consequences of the Pre-Close Dividends and Part IV Tax Trap on corporate transactions.
check_circleDiscuss the implications of Bill C-208 on section 55 of the Income Tax Act and its impact on the sale of a business.
check_circleEvaluate unresolved issues in the language of Bill C-208 and their implications for tax planning strategies.
check_circleExplore practical applications of Bill C-208 in structuring intercorporate transactions and mitigating tax liabilities.

About This Course

This three hour course will cover topics including:


Pre-Close Dividends and Part IV Tax Trap

  • Intercorporate dividends paid through a family trust in the year of close are potentially subject to part IV tax, even if the two companies are connected at the time of payment.
  • Identifying situations that contain this trap and potential work around strategies.

Sale of a Business in Conjunction with Bill C-208

  • Discussion of Bill C-208 and how it impacts section 55
  • Unresolved issues with the wording of Bill C-208
  • Practical applications of Bill C-208

Pre-Close Dividends and Part IV Tax Trap

  • Use of a Related Party Butterfly under 55(3)(a)
  • Identifying situations where a 55(3)(a) butterfly would not work and potential work around strategies

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

4.7
Student's Choice
19 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.