Taxation of Business Enterprises examines the federal income tax treatment of Canadian-resident corporations and their shareholders. The course covers the corporate tax rates on different types of income (including the small business deduction and refundable taxes on investment income), the integration system for taxing shareholders (including the tax treatment of dividends and other corporate distributions), the concept of paid-up capital and the anti-surplus stripping rules, tax-deferred transfers of property to a corporation, and corporate reorganization provisions (including share-for-share exchanges, share conversions, capital reorganizations, amalgamations and liquidations).
The course explores the tax policy choices influencing Canada’s corporate income tax system, and encourages an understanding of complex statutory provisions through an appreciation of the underlying policy rationales. The instructor will use examples from his tax practice experience to illustrate how Canada’s corporate tax rules actually apply in real-world circumstances. This will inform an exploration of ways in which the corporate tax system might be improved and reformed. The course is intended to provide students pursuing business law careers with a practical understanding of foundational corporate tax principles, and is essential preparation for students pursuing further studies in taxation law.
Method of Evaluation: Open-book examination (3 hours) worth 100% or 50% open-book examination and 50% paper (5,000 words).