Taxation of Business Organizations in Canada, 2nd Edition
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Written by academics and tax experts David G. Duff and Geoffrey Loomer, Taxation of Business Organizations in Canada, 2nd Edition provides readers with a comprehensive analysis of statutory provisions and judicial decisions governing the taxation of partnerships and corporations. Covering the taxation of partnerships and their members, corporate income and losses, corporate distributions, shareholder benefits and loans, indirect benefits and income splitting and corporate reorganizations, this book is a valuable resource for understanding the income taxation of business organizations in Canada.
A thorough review
Taxation of Business Organizations in Canada, 2nd Edition is a combination casebook/textbook that provides students and legal practitioners with commentary on statutory provisions and judicial decisions governing Canadian income taxation of partnerships, corporations and shareholders. The text provides readers with a comprehensive overview of the field, addressing advanced topics in the taxation of partnerships and corporations, including the characterization and allocation of income received through partnerships and corporations, the acquisition of losses, associated corporations and the small business deduction, the lifetime capital gains deduction, deemed dividends, surplus stripping, shareholder benefits and loans, income-splitting and the tax on split income, the transfer of property to a partnership or corporation, the windup of a partnership or corporation, and other reorganizations involving partnerships and corporations.
This reference features:
- Detailed explanations of statutory provisions
- Excerpts from leading judicial decisions interpreting these provisions
- Expert commentary and analysis of legislation and case law
- Notes and questions to broaden the analysis and reflect upon specific judicial decisions
What’s New In This Edition
- Explanatory material and tables reflecting updated individual corporate income tax rates
- Detailed explanations of other legislative amendments since 2015, including new limits on the small business deduction in section 125 of the ITA, the meaning of de facto control, changes to the dividend refund in section 129 of the ITA, expansion of the tax on split income in section 120.4 of the ITA, and amendments to section 55 of the ITA
- Case excerpts and analysis of the Federal Court of Appeal decisions in Canada v. 594710 British Columbia Ltd. and Canada v. Oxford Properties Group Inc., and the Tax Court of Canada and Federal Court of Appeal decisions in 1245989 Alberta Ltd. v. The Queen and Perry Wild v. The Queen
- Case notes on other notable cases, such as Birchcliff Energy Ltd. v. The Queen, Kruger Wayagamack Inc. v. Canada, McGillivray Restaurant Ltd. v. Canada, Laliberté v.The Queen, Atlantic Packaging Products Ltd. v. The Queen, Poulin v. Canada and Turgeon v. Canada, and Pomerleau v. Canada
- Improved analysis of other provisions and cases
Taxation of Business Organizations in Canada, 2nd Edition will be especially useful for:
- Law students and professors who need a comprehensive and reliable academic text
- Accounting and business students who are interested in corporate tax law and regulations
- Tax lawyers who require access to the most up-to-date tax law information
Table of contents
Table of Cases
Chapter 1: Partnership Income and Losses
Chapter 2: The Partnership Interest
Chapter 3: Special Rules for Limited Partnerships
Chapter 4: Partnership Reorganizations
Chapter 5: Introduction to the Corporate Income Tax
Chapter 6: Small Business Deduction
Chapter 7: Aggregate Investment Income and Dividend Refund
Chapter 8: Disposition of Shares
Chapter 9: Paid-Up Capital, Stock Dividends, Deemed Dividends and Surplus Stripping
Chapter 10: Shareholder Benefits, Loans and Debt
Chapter 11: Indirect Benefits, Income Attribution and Split Income
Chapter 12: Transfer of Property to a Corporation
Chapter 13: Tax-Deferred Exchanges and Conversions
Chapter 14: Amalgamations and Wind-ups
Chapter 15: Capital Gains Stripping, Related-Party Transactions and Divisive Reorganizations
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