Philip Ward spoke at the Canadian Tax Foundation's Ontario tax conference on revisiting share-related rollovers. His session provideda comprehensive review of the planning opportunities utilizing sections 51, 85, 85.1 and 86.
Topics included:
- Conditions for eligibility;
- Share-for-share exchanges;
- Transfers for non-share consideration (boot);
- Transfers of non-share assets; and
- Tips and traps—including adjustment clauses, flow-through/allocation of tax characteristics, “stop loss” rules, PUC grinds/limits and more.