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Corporate Tax Planning: Navigating Intergenerational Business Transfers—Subsections 84.1(2.31) and (2.32)

Sabrina Jackson-Nazareth & Mira Wilkins

Canadian Tax Journal2025https://doi.org/10.32721/ctj.2025.73.1.ctparticle
ABDC A*
Weight
0.50

Abstract

This article explores the complexities of intergenerational business transfers (IBTs) under Canadian income tax law, with particular focus on subsections 84.1(2.31) and (2.32) of the Income Tax Act. It examines the challenges posed by section 84.1, which historically created significant tax disadvantages for family-owned business transfers, and considers legislative changes introduced by Bill C-208 and subsequent amendments in Bill C-59 to provide exceptions for genuine IBTs. The article delves into the mechanics of section 84.1, the criteria for qualifying as an immediate or a gradual intergenerational business transfer, and the conditions that must be met before, during, and after the share disposition. It also addresses practical challenges and planning considerations with regard to valuation, documentation, and family dynamics in navigating these provisions.

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https://doi.org/https://doi.org/10.32721/ctj.2025.73.1.ctp

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@article{sabrina2025,
  title        = {{Corporate Tax Planning: Navigating Intergenerational Business Transfers—Subsections 84.1(2.31) and (2.32)}},
  author       = {Sabrina Jackson-Nazareth & Mira Wilkins},
  journal      = {Canadian Tax Journal},
  year         = {2025},
  doi          = {https://doi.org/https://doi.org/10.32721/ctj.2025.73.1.ctp},
}

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Corporate Tax Planning: Navigating Intergenerational Business Transfers—Subsections 84.1(2.31) and (2.32)

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Evidence weight

0.50

Balanced mode · F 0.40 / M 0.15 / V 0.05 / R 0.40

F · citation impact0.50 × 0.4 = 0.20
M · momentum0.50 × 0.15 = 0.07
V · venue signal0.50 × 0.05 = 0.03
R · text relevance †0.50 × 0.4 = 0.20

† Text relevance is estimated at 0.50 on the detail page — for your query’s actual relevance score, open this paper from a search result.