This course examines the federal income tax treatment of resident corporations and their shareholders. It also deals, to a limited extent, with the income tax treatment of partnerships and their members. It considers the basic income tax concerns of business enterprises: the decision to incorporate; considerations when capitalizing a corporation; the use of professional, personal services, and executive management corporations; the small business deduction and associated companies; remuneration of the owner manager; transferring assets to a corporation; statutory amalgamations, arrangements, and continuations; liquidations; and demergers and reorganizations of capital.
The above “technical” issues will be discussed , the course will provide students with the legislative framework and fundamental principles and concepts. The technical rules may appear “mechanical”, but they have an underlying logic. At the end of the course, students are expected to appreciate the nuanced relationship between income tax law, corporate law and financial accounting and why tax law respects the corporate form in some circumstances and effectively “disregards” the corporate form in other circumstances. The ultimate objective of this course is to help students learn how to learn.
Method of Evaluation:
10% attendance and participation;
20% research memorandum on assigned topics;
70% Open-book examination (3 hours).