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Tax On Split Income (TOSI) Tactics: Enhancing Corporate Reorganizations for Tomorrow 3 Credits 3 Credits

Sep 05, 2024, 09:00 AM ET

Tax On Split Income (TOSI) Tactics: Enhancing Corporate Reorganizations for Tomorrow 3 Credits 3 Credits

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Sep 05, 2024, 09:00 AM ET

Learning Objectives

  • Discuss the strategic advantages of Single Holdco and Double Holdco structures in optimizing tax efficiency under Canada's Tax On Split Income (TOSI) rules.
  • Explore advanced tactics such as income splitting, capital gains exemption multiplication through family trusts, and purification outlets for enhanced tax planning.
  • Identify implementation steps including Related Party Butterfly (55(3)(a)) and Unrelated Party Butterfly (55(3)(b)) strategies for effective corporate reorganizations.
  • Identify and avoid potential tax traps such as the Purification Trap for Capital Gains Exemption, Subsection 55(2), Corporate Attribution under section 74.4, and potential HST implications.

Course Overview

Tax on Split Income (TOSI) tactics shape future corporate reorganizations. They aim to optimize tax efficiencies while complying with regulatory frameworks. 

In this insightful webinar, attendees will explore advanced strategies for corporate reorganizations tailored for owners/managers seeking to optimize their tax efficiency under Canada’s Tax On Split Income (TOSI) rules. The course will focus on two fundamental corporate structures: the “Single Holdco,” which offers centralized management of assets and income, and the “Double Holdco,” which provides additional flexibility in income distribution. The webinar will elucidate their respective income tax advantages, helping participants understand how these structures can potentially enhance tax planning opportunities, particularly in managing income splitting among family members.

By examining real-world scenarios and case studies, attendees will learn how to identify opportunities where these corporate reorganizations can be leveraged effectively to achieve tax savings and operational efficiencies. 

Whether considering a Single Holdco for centralized asset and income management or a Double Holdco for additional flexibility in income distribution, attendees will leave with practical knowledge to navigate the complexities of TOSI rules confidently.

Key topics covered:

  • Single Holdco (for Related Shareholders)
  • Double Holdco (for Unrelated Shareholders)
  • Tax Advantages:
    • Income Splitting
    •  Multiplication of Capital Gains Exemption through family trust
    • Purification outlet for Capital Gains Exemption
  •  Implementation Steps (“Breaking Up is Hard to Do”)
    • Related Party Butterfly 55(3)(a)
    • Unrelated Party Butterfly 55(3)(b)
  •  Tax Traps
    •  Purification Trap for CGE: watch out for inter-corporate debt!
    • Subsection 55(2)
    •  Corporate Attribution under section 74.4
    • HST Trap

For more Canada CPD Courses, Click here.

On Demand Credits for All Qualifications

Live Webinar Credits for All Qualifications

License details Credits Status
Taxes for CPA in Canada 3 CPD Eligible
License details Credits Status
Taxes for CPA in Canada 3 CPD Eligible

Additional Information

Credits

3

Course Level

Basic

Instructional Method

QAS Self Study

Group Internet Based

Pre-requisites

None

Advance Preparation

None

About Instructor

AJAG

AJAG Professional Development

, AJAG Professional Development

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AJAG offers a comprehensive selection of professional development courses in Tax, Accounting, Assurance, Ethics and more - all designed to keep CPAs informed and up to date. We strive to deliver the highest quality, most relevant and accessible continuing education content for CPAs in Canada. Our instructors are some of the most well-respected presenters in their field and present their own course material - covering a wide range of relevant, timely topics.

On Demand FAQs

What is Self Study (QAS)?

Self Study QAS (Quality Assurance Service) is a NASBA and other regulatory bodies approved program designed for Professionals to complete their Continuing Professional Education credits through self-paced, interactive courses that meet the highest standards of quality and compliance. We are approved by NASBA, IRS, CFP Board, HRCI, SHRM, Payroll Org, FP Canada, and 25+ other regulatory bodies.

How do I earn CPE credits through self-study?

To earn CPE credits, you must complete the self-study course, pass the required assessments, and submit the necessary documentation. Credits are awarded based on the completion of course hours and successfully passing the assessments.

Are the self-study courses approved by NASBA and other regulatory bodies?

Yes, all our self-study courses are approved by NASBA, IRS, CFP Board, HRCI, SHRM, Payroll Org, FP Canada, and 25+ other regulatory bodies, ensuring they meet the rigorous standards for quality and educational content set by these organizations.

What are the requirements to maintain compliance with self-study courses?

To maintain compliance, you must follow the guidelines set by NASBA and other regulatory bodies, which include completing the course within the specified timeframe, passing the assessments, and keeping accurate records of your learning activities.

How can I access my course completion certificates?

After successfully completing a self-study course and passing the assessments, you can access and download your course completion certificates from your account dashboard on our platform. These certificates are recognized by NASBA, IRS, CFP Board, HRCI, SHRM, Payroll Org, FP Canada, and 25+ other regulatory bodies for compliance and reporting purposes.

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What is a Live Webinar Group Internet-Based Credit?

A Live Webinar Group Internet-Based Credit is an interactive, real-time online seminar where professionals can earn Continuing Education credits by participating in live sessions led by experts in various fields. These sessions meet the standards set by NASBA, IRS, CFP Board, HRCI, SHRM, Payroll Org, FP Canada, and 25+ other regulatory bodies.

How do I earn credits through live webinars?

To earn credits, you must attend the entire live webinar, actively participate in any polls or questions, and complete any required evaluations or assessments. Credits are awarded based on your attendance and participation in the live session.

Are the live webinars approved by NASBA and other regulatory bodies?

Yes, all our live webinars are approved by NASBA, IRS, CFP Board, HRCI, SHRM, Payroll Org, FP Canada, and 25+ other regulatory bodies, ensuring they meet the high standards for quality, interactivity, and educational content set by these organizations.

What are the requirements to maintain compliance with live webinar courses?

To maintain compliance, you must adhere to the guidelines set by NASBA and other regulatory bodies, which include attending the full duration of the webinar, participating in interactive elements, and completing any post-webinar evaluations or assessments.

How can I access my webinar completion certificates?

After successfully attending a live webinar and fulfilling all participation requirements, you can access and download your completion certificates from your account dashboard on our platform. These certificates are recognized by NASBA, IRS, CFP Board, HRCI, SHRM, Payroll Org, FP Canada, and 25+ other regulatory bodies for compliance and reporting purposes.

How are credits reported to governing bodies?

We issue instant credit certificates, ensuring they are valid for presentation to governing bodies. Typically, we report IRS, CTEC, CFP, IDFP, IWI, VBOA Ethics credits within 7 days – the fastest in the industry.

Reviews and Ratings

out of 5

Excellent (62%)

Very Good (38%)

Average

Poor

Terrible

JC

Jacob Cruise, CPA in Canada

5

Very informative course and breaks down restructuring topics very well.

JF

John Ferfolia, CA - ICAEW

5

Great breakdown of ways to structure.

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