Section 160 Implications in Family Transfers

Section 160 Implications in Family Transfers is a focused, practical course designed to help accounting and tax professionals understand one of the most significant anti-avoidance provisions in the Income Tax Act. Section 160 is frequently applied in family and other non-arm’s length transactions, and it can create unexpected joint and several liability for unpaid tax debts. This course provides the clarity and applied insight professionals need to navigate these risks confidently. Learners will explore the legislative framework of Section 160, including the four essential conditions required for liability to arise: a transfer of property, a non-arm’s length relationship, inadequate consideration, and the existence of unpaid tax liabilities at the time of transfer. The course explains how “property” is broadly defined, how non-arm’s length relationships are determined in both family and corporate contexts, and how fair market value is assessed when calculating transferee exposure. Through practical examples and case studies, the course examines common family scenarios such as gifting real estate, transferring shares of a closely held corporation, implementing estate freezes, and settling assets into family trusts. Participants will also review key court decisions and CRA administrative practices that shape enforcement, gaining insight into how reassessments occur and how they may be defended. In addition to technical analysis, the course emphasizes proactive risk mitigation strategies, including proper documentation, fair market value support, due diligence before accepting transfers, and thoughtful structuring of intergenerational transactions. By the end of the course, learners will be better equipped to identify Section 160 exposure, advise clients effectively, and integrate these considerations into broader tax and estate planning strategies. Delivered online and self paced, the course includes structured video instruction, downloadable reference materials, applied case studies, and knowledge checks to reinforce learning. It contributes toward multiple Canadian Accountant Training Institute certificate programs, making it a valuable component of ongoing professional development in Canadian tax practice.