LAWS 2106

This course covers several topics in relation to the taxation of corporations and their shareholders under the Income Tax Act. The emphasis is on reading and understanding the statutory language as construed by the courts, as well as analyzing the policies and principles that animate the legislation. The initial part of the course addresses the taxation of corporate income, with topics including: rationales for corporate taxation, corporate residence, Canadian-controlled private corporation status, active business income, and investment income. The next part of the course deals with the taxation of shareholder distributions, including dividends and shareholder benefits. Subsequent classes focus on tax-deferred corporate reorganizations. Finally, the course surveys the tax aspects of buying and selling a corporate business. At various points in the course the rules regarding corporations are compared to those concerning partnerships and income trusts. The aim is to give students a strong foundation for future practice or research in corporate tax law.