Section 85: Property transfers to a corporation

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This is the agenda for Module 1A
Module 1A The essentials of section 85: Purpose, properties, and required tax filings
 
Qualifying property

 
§85 administration

 
The parties

 
Purpose

This is the agenda for Module 1B
Module 1B The essentials of section 85: The basic parameters and the consideration
 
§85(1): The basic range

 
Special rule(s)

 
Cost of the consideration received

This is the agenda for Module 1C
Module 1C The essentials of section 85: Loss properties
 
Transfers of loss properties

 
Loss properties

 
Transfers of loss properties

 
Meaning of control

 
Review questions/solutions

 
Meaning of control

 
Review questions/solutions

This is the agenda for Module 2A
Module 2A Special rule properties: Eligible capital property
 
Eligible capital property (ECP)

This is the agenda for Module 2B
Module 2B Special rule properties: Depreciable property and other properties
 
Special rule overriding conflicts between deemed agreed amounts

 
Depreciable property of a prescribed class

 
Additional §85(1) matters

This is the agenda for Module 3A
Module 3A Consideration received: Notably shares and their fair market value
 
Fair market value

 
Consideration of less than equal value

 
Consideration exceeds equal value

This is the agenda for Module 3B
Module 3B Consideration received: PUC reductions
 
PUC reductions (tax PUC)

 
Review questions/solutions

This is the agenda for Quiz 1
Quiz 1
This is the agenda for Module 4A
Module 4A Transferring shares held as capital property: Section 84.1
 
Taxable benefits

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

This is the agenda for Module 4B
Module 4B Transferring shares held as capital property: Potential alternatives — Sections 86, 85.1, and 51
 
§85.1 Inter-corporate share exchange

 
§51 Convertible Property

 
§86(1) Intra-corporate share exchange

 
Review questions/solutions

This is the agenda for Module 5A
Module 5A Additional compliance and planning matters: FMV to Offside 86
 
Estate freezes

 
Crystallization

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

 
Offside 86

This is the agenda for Module 5B
Module 5B Additional compliance and planning matters: Butterflies to double taxation
 
Double taxation

 
Butterflies

 
Incorporation to access §110.6

 
Purification

 
Capital gain stripping

 
Review questions/solutions

This is the agenda for Quiz 2
Quiz 2
This is the agenda for Summary
Summary
This is the agenda for Appendices
Appendices
 
List of abbreviations

Highlights

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