Section 85: Property transfers to a corporation

Get a strong working knowledge of section 85 and the technical, legal and tax implications it has for corporations.

Event Details

Location and date:
Online On-Demand Event

Section 85 of the Income Tax Act permits tax-free transfer of property to a corporation, as long as specific rules are followed.

This online course provides you with working knowledge of tax issues and solutions from both the technical and conceptual perspectives of Section 85 rollovers, with an emphasis on the common tax situations and circumstances facing Canadian small business corporations and resident individuals.

The course is based on the Income Tax Act as it currently stands. Any relevant proposals and pending legislation have been incorporated into these materials as if they had been passed into law. Should any of that pending legislation not be implemented there would be no material effect on the course.

View the agenda

Additional options and pricing may be available. See pricing and registration for more details.


12 CPD hour(s)
Pricing & registration

You will learn about:

  • qualifying property
  • special rules for loss properties, transfer, control
  • market value and PUC reductions
  • estate freezes and adjustment clauses
  • capital gain stripping

Who should attend?

  • income tax consultants

More Details:

Session Descriptions

Qualifying property

§85 administration

The parties


§85(1): The basic range

Special rule(s)

Cost of the consideration received

Transfers of loss properties

Loss properties

Transfers of loss properties

Meaning of control

Review questions/solutions

Meaning of control

Review questions/solutions

Eligible capital property (ECP)

Special rule overriding conflicts between deemed agreed amounts

Depreciable property of a prescribed class

Additional §85(1) matters

Fair market value

Consideration of less than equal value

Consideration exceeds equal value

PUC reductions (tax PUC)

Review questions/solutions

Taxable benefits

§84.1: PUC reductions, deemed dividends, and “modified ACB”

§85.1 Inter-corporate share exchange

§51 Convertible Property

§86(1) Intra-corporate share exchange

Review questions/solutions

Estate freezes


Fair market value (FMV) FMV: Price-adjustment clauses

Offside 86

Double taxation


Incorporation to access §110.6


Capital gain stripping

Review questions/solutions

List of abbreviations



Please contact:

CPA Canada Professional Learning and Development Customer Service
Tel: 1-888-337-3242


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