Various Tax Topics for M&A Transactions

Mergers and acquisitions are never just about price and structure—they are defined by tax risk. With frequent amendments to the Income Tax Act (Canada) and evolving administrative positions, even well-planned transactions can produce unexpected and costly tax outcomes. A clear understanding of the more nuanced tax issues that arise in M&A is essential for advisors who want to protect value, manage risk, and deliver confident advice to their clients.

Course Description

This presentation provides a practical, transaction-focused discussion of several high-impact M&A tax issues, including:

Earnouts and reverse earnouts, with a focus on how they are treated for tax purposes and how to structure them effectively;

The new suspended refundable dividend tax on hand (RDTOH) regime, introduced in the most recent federal budget, and its implications for deal planning and post-closing cash extraction;

The use of the “trust sandwich” structure and its interaction with Part IV tax, particularly in sale transactions; and

Restrictive covenants, including when they arise, how they are taxed, and when a joint election is required. The session is designed to equip practitioners with practical insights they can apply immediately in live transactions.

Taken together, these issues highlight how easily tax outcomes can diverge from commercial intent in an M&A transaction if they are not addressed early and deliberately. By understanding where the technical traps lie—and how recent legislative changes reshape the planning landscape—advisors can better anticipate risk, preserve value, and guide clients through increasingly complex transactions with confidence. This presentation is intended to leave practitioners not only more informed, but better prepared to spot issues, ask the right questions, and deliver tax advice that meaningfully supports deal success.

About this course

$170.00
2 CPD hours
November 19, 2026 - 1:00 PM ET

Instructor(s)

Manu Kakkar

[email protected]

Manu has over 20 years of experience in taxation in both domestic and international, personal, and corporate taxation as well as expert witness reports and testimony. 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 450 tax articles and presentations since 2001 across Canada. Manu is an authority in taxation as his name has been cited 41 times in the Income Tax Act.

Boris Volfovsky

[email protected]

Partner, CPA, CA
Boris has over 17 years of experience in public practice. Before becoming a partner at CPA Solutions LLP Boris worked at one of the big four national firms as a senior tax manager in the private enterprise group.

Boris has vast experience in working with owner managers and their small, medium and large private corporations across industries.

In addition Boris is also involved in the tax community through the facilitation of the In-Depth tax courses, facilitation of tax week under the former School of Accountancy and through presenting on various tax topics at YDCPAA, PD Consortium and AJAG.