Income Tax, Succession Planning and Corporate Reorganizations
Corporate reorganizations, succession transitions, and tax disputes all demand accurate, defensible valuations that can withstand scrutiny from stakeholders and regulators alike. Whether supporting tax planning, facilitating ownership changes, or responding to challenges from the Canada Revenue Agency ("CRA"), businesses need precise analysis and independent expertise.
VLSS brings deep experience in these areas, providing clear, defensible valuation guidance that helps companies and their advisors structure reorganizations effectively, navigate CRA expectations, and plan for long-term continuity.
Our valuation and tax dispute support services include:
Determining the en-bloc fair market value of companies
Allocating value among multiple share classes with differing rights, restrictions, and economic attributes
Preparing clear, defensible valuation reports for tax advisors, legal counsel, and regulatory submissions
Assistance through all stages of the tax dispute process, including negotiation, mediation, and expert testimony
Review and rebuttal of CRA audit valuation positions and proposed assessments
Strategic support for counsel, including settlement analysis and expert reporting
Selected representative experience includes:
Cineplex v. Canada Revenue Agency – Provided valuation opinion on behalf of Cineplex relating to the acquisition of AMC Ventures.
Talisman Energy v. Canada Revenue Agency – Provided valuation opinion on behalf of Talisman Energy relating to an acquisition in the Sudan.
Food packaging manufacturer - Valuation of food packaging manufacturing company for estate and tax planning purposes. Mandate included allocating en-bloc value between different share classes.
Software - Valuation of internally developed software by an investment advisory firm for the purpose of corporate reorganization and tax planning.