With increasing globalization, many Canadians are considering moving abroad not only for career and lifestyle opportunities but also for tax-related benefits. While changing residency can yield tax advantages, the process is complex, with significant tax implications and administrative requirements.

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Section 86 of Canada’s Income Tax Act (ITA) provides an effective tax-planning tool for business owners seeking to exchange shares within a corporation without triggering immediate tax consequences. Known as a “section 86 share exchange,” this provision allows taxpayers to swap old shares for new shares in the same corporation.

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