Secton 86 and 51 Corporate Reorganizations

This in-depth module covers the tax-deferred corporate reorganization provisions in sections 86 and 51 of the ITA. CPAs will learn how to structure reorganizations for capital continuity, estate freezes, and shareholder realignment without triggering immediate tax consequences. The module explains key concepts such as adjusted cost base rollover, paid-up capital limitations, anti-gifting rules, and deemed dividend traps. Through advanced case studies, participants will evaluate the practical application of reorganizations in succession planning and capital restructuring while managing CRA scrutiny.