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Get a strong working knowledge of section 85 and the technical, legal and tax implications it has for corporations.
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.
This course is based on the Income Tax Act effective as of April 21, 2016, and incorporates pending legislation announced up to and including that date. 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.
Additional options and pricing may be available. See pricing and registration for more details.
§85(1): The basic range
Cost of the consideration received
Transfers of loss properties
Meaning of control
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)
§84.1: PUC reductions, deemed dividends, and “modified ACB”
§85.1 Inter-corporate share exchange
§51 Convertible Property
§86(1) Intra-corporate share exchange
Fair market value (FMV) FMV: Price-adjustment clauses
Incorporation to access §110.6
Capital gain stripping
List of abbreviations
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