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.

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.

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

The parties


Qualifying property

§85 administration

§85(1): The basic range

Special rule(s)

Cost of the consideration received

Review questions/solutions

Meaning of control

Meaning of control

Transfers of loss properties

Loss properties

Transfers of loss properties

Review questions/solutions

Eligible capital property (ECP)

Depreciable property of a prescribed class

Special rule overriding conflicts between deemed agreed amounts

Additional §85(1) matters

Consideration of less than equal value

Fair market value

Consideration exceeds equal value

PUC reductions (tax PUC)

Review questions/solutions

Taxable benefits

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

§86(1) Intra-corporate share exchange

§85.1 Inter-corporate share exchange

§51 Convertible Property

Review questions/solutions

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

Estate freezes


Offside 86


Capital gain stripping

Double taxation


Incorporation to access §110.6

Review questions/solutions

List of abbreviations



Please contact:

Member Development and Support
Tel: 1-800-268-3793