Tax tips for corporate reorganizations
"Jump Start on CPD 2016": Thursday, March 3, 2016; Time: 9:00 am – 4:00 pm
(Original course: Friday, November 27, 2015)
Who should attend: Corporate and tax lawyers, both litigators and solicitors, and those who advise clients about tax issues on an occasional basis.
Learning level: Fundamental/Intermediate
This course is a practical introduction to, and refresher on, common tax issues that arise in commercial transactions, with a focus on corporate reorganizations for solicitors and litigators.
This course is not only for solicitors; litigators will also find useful tips for the tax issues that commonly occur in commercial transactions.
At this course you will learn about...
- how to deal with tax issues in corporate reorganizations such as: property transfer, corporate distributions, divisive reorganizations and mergers and acquisitions
- anti-avoidance rules
- taxation of partnerships
- prudent practice tips for avoiding professional negligence claims
Law Society of BC CPD Hours: 6 hours (a minimum of 1 hour will involve aspects of professional responsibility and ethics, client care and relations, and/or practice management).
Course Chair
David Christian — Thorsteinssons LLP, Vancouver
Pricing
"Jump Start on CPD 2016" Rebroadcast
EARLY BIRD (Register by February 1, 2016 and SAVE): $430
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After February 1, 2016: $475
Registration includes an electronic copy of the course materials.
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CLEBC Program Lawyer
Genevieve Chang
gchang@cle.bc.ca
Course Chair
David Christian — Thorsteinssons LLP, Vancouver
About the Course Chair
David Christian is a partner with Thorsteinssons LLP, Vancouver. His practice covers all taxation matters, with a particular focus on corporate reorganizations and taxation of owner-managed businesses. For eight years David was an adjunct professor of corporate tax law at Peter A. Allard School of Law, UBC. Over the years he was a contributor to the tax materials for the Professional Legal Training Course of BC, and has lectured on tax matters at conferences sponsored by the Canadian Tax Foundation, the CLE Society of BC, the Conference for Advance Life Underwriting, PBLI, and various professional organizations including the CGA Association of BC, the Institute of Chartered Accountants of BC, the Institute of CAs of Ontario, the BC Medical Association, and the CBA.
Faculty
David Christian — Thorsteinssons LLP, Vancouver
Tim Clarke — Moodys Gartner Tax Law LLP, Vancouver
Michael Coburn — Fasken Martineau DuMoulin LLP, Vancouver
Stephanie J. Daniels — Farris, Vaughan, Wills & Murphy LLP, Vancouver
Alexander Demner — Thorsteinssons LLP, Vancouver
Ron Dueck — Farris, Vaughan, Wills & Murphy LLP, Vancouver
Greg Hollingsworth — Lawson Lundell LLP, Vancouver
Soraya Jamal — Blake, Cassels & Graydon LLP, Vancouver
Welcome and Introduction
David Christian — Thorsteinssons LLP, Vancouver
I. Corporate Taxation: An Overview
- nature of corporate taxation
- taxation of different sources of income
- corporate tax deferrals
- theory of integration
David Christian — Thorsteinssons LLP, Vancouver
II. Corporate Reorganizations
A. Transfer of Property to a Corporation
- which sections of the Income Tax Act can you use?
- requirements of the various sections
- valuation and price adjustment clauses
- share rights and restrictions
Stephanie J. Daniels — Farris, Vaughan, Wills & Murphy LLP, Vancouver
Networking Break
B. Corporate Distributions
Soraya Jamal — Blake, Cassels & Graydon LLP, Vancouver
C. Mergers of Corporations
- tax considerations in business acquisitions
- amalgamations
- wind-ups
Greg Hollingsworth — Lawson Lundell LLP, Vancouver
D. Divisive Reorganizations
- overview of s. 55
- related person reorganizations
- butterfly reorganizations
- purifications, splits, and spins
Alexander Demner — Thorsteinssons LLP, Vancouver
Lunch (on your own)
III. Anti-Avoidance Rules
- surplus stripping
- shareholder benefits
- conferral of benefits
- attribution rules
- GAAR
Michael Coburn — Fasken Martineau DuMoulin LLP, Vancouver
Networking Break
IV. Partnership Taxation
- creating a partnership: tax considerations
- computing the taxable income of a partnership
- taxation of the partners: allocating and distributing partnership income
- partnership losses: negative cost-base, the at-risk rules, and the tax shelter investment rules
- reorganizations and alterations to a partnership
- cross-border tax issues
- termination and dissolution of a partnership
Ron Dueck — Farris, Vaughan, Wills & Murphy LLP, Vancouver
V. Defensive Tax Practice
- what is professional negligence?
- frequent causes of concern
- prudent practices
- reporting errors
- rectifying errors
Tim Clarke — Moodys Gartner Tax Law LLP, Vancouver
Closing Remarks
David Christian — Thorsteinssons LLP, Vancouver