Amalgamations and Wind-ups

This module explores the tax rules applicable to corporate amalgamations and wind-ups under sections 87 and 88 of the ITA. Participants will analyze the legal requirements for qualifying transactions, the continuity rules for tax attributes, and the treatment of assets and liabilities during a wind-up. Special attention is paid to the parent-subsidiary wind-up rules under subsection 88(1) and vertical/horizontal amalgamations. The module helps CPAs understand when and how to execute tax-deferred corporate combinations while minimizing exposure to double taxation.