- To combine companies in order to use the profits of one company against the losses of another, or to simplify a group of companies or eliminate inactive companies
- To create holding companies for creditor-proofing reasons, or to carry out an estate freeze of share value
- To create new entities for losses of companies in one group to be utilized by profits of companies in another group
- To divide the assets of a corporation among the shareholders (referred to as a butterfly reorganization)
- To incorporate a business such that it may be carried on in corporate form
- To change the nature of a corporation’s income (from investment income to active business income or vice versa)
We can assist to develop a reorganization plan to accomplish the desired business and shareholder objectives as well as business operations. If applicable, we can assist to prepare a request of Canada Revenue Agency’s ruling on its tax interpretation on certain aspects of the reorganization plan. We work closely with legal counsel to implement the tax planning with the required legal documentation. We can also prepare all the required tax filings and tax elections.
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