The most common issues in recessionary times are debt forgiveness and utilization of losses. This course will go over both topics as well as their practical interaction. 

This course will go over the technical rules of what is a forgiven debt, the ordering provisions of applying the forgiven debt, and  planning points. 

Insofar as to loss utilization, this course goes over loss restriction events (including but not limited to an acquisition of control) and rules permitting the  utilization of losses in an affiliated group.

This course provides an in-depth exploration into the intricacies of debt forgiveness and loss utilization within the context of corporate restructuring. Designed for finance professionals, accountants, and legal advisors, the program delves into the legislative framework, strategic implications, and practical applications of managing debt forgiveness and utilizing losses effectively. Through detailed examination of case studies, legal precedents, and real-world scenarios, participants will gain critical insights into optimizing financial strategies while ensuring compliance with complex regulations.

List of Topics:

• Basic Concepts and Definitions
• Overview and Implications of Section 256.1

• Detailed Analysis of Loss Restriction Events and Acquisition of Control
• Navigating Change in Majority-Interest Beneficiaries

• Practical Implications for Affiliated Parties
• Mitigating Loss Trading Among Affiliated Entities

• Debt Forgiveness Mechanisms and Exclusions
• Application of Forgiven Amount and Income Inclusion Strategies

• Strategies for Effective Loss Utilization
• Addressing Common Pitfalls and Compliance Issues

• In-depth Analysis of Bagtech Inc. vs. La Reine and Lyrtech RD Inc. vs. La Reine