ADMN 4710H Chapter Notes - Chapter 14: Tax Deferral, Investment

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Purpose: re-organizing corporate structure to re-arrange business activities, ex. A parent corporation of an auto manufacturer moving production of large trucks from one corporation to another corporation or combine two business activities that are under two separate corporations into one corporation. "a corporate reorganization usually involves a change in form, rather than a change in substance. " Share reorganizations (exchanging one type pf shares for another, within same corporation) Asset transfers: transfer of assets from one corporation to another corporation (to move a business activity) Corporation with losses can create taxable income and offset losses by transferring assets between: transfer price of each asset is deemed equal to fmv sister corporations, ex. Two corporations that are owned by the same shareholders: note: instead of transferring assets to another corporation, the corporation can simply lease the assets for rent/royalties to another corporation. Describe what takes place when two or more corporations amalgamate: amalgamation of two or more corporations into a new corporation.

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