Taxation of Business Organizations in Canada, 3rd Edition

Written by academics and tax experts David G. Duff and Geoffrey Loomer, with the assistance of Christopher Bantle, Taxation of Business Organizations in Canada, 3rd Edition provides readers with a comprehensive analysis of statutory provisions and judicial decisions governing the taxation of partnerships and their members and corporations and shareholders.

Covering the taxation of partnerships and their members, the taxation of corporate income, the tax treatment of corporate losses, the taxation of corporate distributions, share dispositions, deemed dividends, shareholder benefits and loans, indirect benefits, income splitting, and corporate reorganizations, this combination casebook/textbook is a valuable resource for understanding the income taxation of business organizations in Canada.

Taxation of Business Organizations in Canada, 3rd Edition delivers a comprehensive overview of the field, addressing advanced topics in the taxation of partnerships and corporations. Part I addresses the taxation of partnerships and their members, considering the characterization and allocation of income received through partnerships, tax consequences resulting from the acquisition or disposition of a taxpayer’s partnership interest, and the taxation of partnership reorganizations including transfers of property to a partnership, the dissolution of a partnership, and the merger of two or more partnerships.

Part II explains the taxation of corporations, reviewing the small business deduction including associated corporations, the taxation of a corporation’s aggregate investment income, and limitations on the deduction of corporate losses.

Part III examines statutory provisions and judicial decisions governing the taxation of shareholders, including the taxation of dividends, gains and losses from the disposition of corporate shares including the lifetime capital gains deduction, deemed dividends and surplus stripping, shareholder benefits and loans, indirect benefits, the attribution rules, and the tax on split income.

Part IV considers statutory provisions and judicial decisions governing the taxation of corporate reorganizations, including transfers of property to a corporation, reorganizations of capital, share-for-share exchanges, amalgamations, capital gains stripping and divisive reorganizations, and the winding-up of a corporation.

What’s New In This Edition

• Significant enhancements to chapters on the small business deduction, the deduction of corporate losses, and corporate reorganizations
• Updated legislative amendments, judicial decisions and administrative positions since the second edition was published in 2019, including rules for intergenerational business transfers and substantive CCPCs
• Reorganization of content into four separate sections for improved clarity and pedagogical flow: the taxation of partnerships and their members, the taxation of corporations, the taxation of shareholders, and the taxation of corporate reorganizations
• New chapters on corporate tax rates, the deduction of corporate tax losses, the taxation of dividends, reorganizations of capital, share-for-share exchanges, amalgamations, and windings-up
• New chapter providing an introduction to the policy, complexity, and relevance of business taxation

Who Should Read This Book

• Tax lawyers who require access to the most up-to-date tax law information
• Accounting and business students who are interested in corporate tax law and regulations
• Law students and professors who need a comprehensive and reliable academic text