Unlock the true value of equity ownership by mastering financial returns, voting rights, and the strategic privileges available to shareholders.
Navigating the complex landscape of Canadian taxation requires a deep understanding of how the Canada Revenue Agency assesses value extraction from corporations. In the course titled Shareholder Benefits, tax experts guide you through the treacherous waters of specific Income Tax Act provisions that often strike fear into taxpayers due to the potential for significant assessments and double taxation. This course moves beyond basic accounting to explore the nuances of tangible and intangible benefits, ensuring practitioners can distinguish between legitimate business expenses and taxable shareholder appropriations.
The content begins with a detailed examination of the "bread and butter" provisions found in Subsection 15(1) and 15(2). Instructors analyze the tax consequences of personal use of corporate assets, such as housing and aircraft, and the strict rules governing shareholder loans, indebtedness, and repayment timelines. Through the lens of real-world case law, including high-profile examples involving Cirque du Soleil, learners will understand how the CRA applies these rules to deny corporate deductions and impute personal income. The course then transitions into complex anti-avoidance measures, exploring indirect benefits under Subsection 56(2), the expansive "catch-all" mechanism of Subsection 246(1), and the cross-border implications of Section 17 regarding interest-free loans to non-residents.
By the end of this course, participants will be able to:
Whether you are advising domestic owner-managers or dealing with multi-layered corporate structures, this course provides the essential technical knowledge to identify risks, properly document transactions, and avoid the punitive pitfalls of shareholder benefit assessments.
AJAG Professional Development was founded in 2003 with a mission of making professional development easier and more cost-effective for Canadian accountants and other financial advisory professionals. Our comprehensive range of flexible and reasonably-priced courses, programs and seminars are delivered online and in classroom-style settings in the Greater Toronto Area (Toronto, Oakville and Markham). AJAG features a roster of highly-qualified instructors who deliver content that is pertinent, up-to-date and engaging.
Partner at CPA Solutions LLP
Alex is a member of the Institute of Chartered Accountants of Ontario (CA), the Certified General Accountants of Ontario (CGA), and is a Certified Public Accountant (CPA) licensed to practice public accounting by the State of Texas. He has completed all three levels of the CICA In-Depth Tax Course. He has over 17 years of experience working in the accounting departments of large companies and as a public practitioner. Over the years, Alex helped many private clients with their tax structuring and estate planning needs. Furthermore, Alex also assists in Canadian and US tax compliance and other tax-related matters. Alex is heavily involved in the tax community and is a member of the Canadian Tax Foundation (CTF). He has published articles for the CTF and presented at various events for the CTF. In addition to this, Alex has also presented at events for CPA Ontario and other industry-specific events. Finally, he also facilitates the CPA Canada In-Depth Tax Course.
CPA, CA, TEP, MTAX
Manu has over 20 years of experience in taxation in both domestic and international, personal and corporate taxation as well as litigation support. He runs his own independent tax practice with offices in Montreal and Toronto, serving a diverse client base which includes manufacturing, retail and distribution, construction, farming, real estate, athletes and artists, across Canada and the US. His firm acts as a counsel to over 100 professional firms in Canada and USA specializing in domestic and international reorganizations and transactions. Manu is known as one of the leading experts in Section 55 of the Act and butterfly reorganizations. He is an award winning and prolific tax writer. His Master of Taxation thesis on butterfly reorganizations won 2 awards and was published in the Canadian Tax Journal. Manu has published and presented over 250 tax articles and presentations since 2001 across Canada. Manu is an authority in taxation as his name has been cited 29 times in the Income Tax Act. Manu has taught tax at The Canadian Institute of Chartered Professional Accountants, The Canadian Tax Foundation and The Society of Trust and Estate Practitioners, of and various provincial accounting bodies across Canada. He sits on the Steering Committees for the Canadian Institute of Chartered Professional Accountants’ National Conference on Income Taxes; the Canadian Tax Foundation Laval Program Committee; CPA Canada’s Small and Medium Practitioner’s Tax Committee; and the Canadian Tax Foundation’s Ontario Tax Conference. Manu is currently serving a three-year term on the Canadian Tax Foundation’s Board of Governors.
