Main features of TCOR

Planning tips to achieve tax savings
Numerous examples of application of complicated ITA provisions
Discussion of technical anomalies, pitfalls and traps
Detailed analysis of CCRA policies including interpretation bulletins, Information circulars and advance tax rulings
Integration into main text of changes in legislation as soon as they occur
Analysis of case law as it develops
Documents obtained through access of information act, both analyzed and reprinted as they are released
Comprehensive coverage ranging over every subject matter
Discussion and citation of significant publications of corporate reorganization written over last 20 tears
Continuously edited, reviewed and updated to be completely reliable resource
Extensive cross-references for further research

Table Of Contents

Definitions
· Corporation
· Resident Corporation
· Status Of Corporations
· Share
· Shareholder
· The General Anti-Avoidance Rule
· References

Transfer of Property to a Corporation
· General
· Conditions Of Application
· The Parameters Of The Agreed Amount
· Subsections 85(2) And (3): Partnerships
· Stop-Loss Rules Within A Corporate Group – Non-Depreciable Capital Property: Subsection 40(3.4)
· Disposition Of Depreciable Property: Subsection 85(5)
· Stop-Loss Within A Corporate Group – Depreciable Property: Subsection 13(21.2)
· Formalities: Subsection 85(6) To (9)
· References
· Section 85 Checklist

Capital Transactions
· Exchange
· Small Business Rollover
· Convertible Property (Section 51)
· Consequences Of Section 51
· Benefit Conferred (51(2))
· Other Matters
· References
· Checklist For Section 51
· Bond Conversion (Section 51.1)
· Consequences Of Section 51.1
· Various Matters
· References
· Checklist – Section 51.1
· Non-Arm’s Length Sale Of Shares(Section 84.1)
· Effect Of Section 84.1
· References
· Share-For-Share Exchange (Section 85.1)
· General
· Conditions Of Application Of Subsection 85.1(1)
· Effect Of Subsection 85.1(1)
· Various Matters
· References
· Checklist – Section 85.1
· Exchange Of Shares By A Shareholder In The Course Of Reorganization Of Capital (Section 86)
· General
· Conditions For The Application Of Section 86
· Consequences Of Section 86
· Indirect Benefit (86(2))
· Other Considerations
· References
· Checklist – Section 86
· Foreign Spin-Offs (Section 86.1)
· Non-Arm’s Length Sales Of Shares By Non-Residents (Section 212.1)
· Conditions Of Application
· Effect Of Section 212.1
· References

Amalgamation
· Amalgamation Of Corporations – Corporate Law
· Amalgamation Of Corporations – Tax Law
· Tax Consequences Of Amalgamation
· Tax Consequences Of An Amalgamation For Shareholders Of Predecessor Corporations
· Tax Consequences Of The Amalgamation For The Holders Of Options To Acquire Shares Of A Predecessor Corporation
· Tax Consequences Of An Amalgamation For Holders Of Obligations Of A Predecessor Corporation
· Rules That Apply To Certain Mergers
· References
· Checklist – Section 87

Winding-Up
· Liquidation And Dissolution In Corporate Law
· Winding-Up Of A Subsidiary
· Windings-Up Not Covered By Subsection 88(1)
· Involuntary Dissolutions
· Bankruptcy Of A Corporation
· References
· Checklist – Section 88

“Butterfly” Transactions
· General
· Subsection 55(2)
· Exception: Paragraph 55(3)(A)
· Exception: Paragraph 55(3)(B)
· Various Matters
· References
· Checklist Paragraph 55(3)(B)

Transformation of a Branch
· Introduction  
· Branch Tax
· Transformation Of A Branch
· Conclusion
· References