INCOME SPRINKLING PANEL

Transcription

1 Tax Planning Using Private Corporations - July 18, 2017: Analysis and Discussion with Finance Ottawa, ON INCOME SPRINKLING PANEL Speakers: Albert Baker (moderator), David Christian, Michael Wolfson, Rachel Gervais Disclaimer: This material is for educational purposes only and is not intended to be advice on any particular matter. No one should act on the basis of any matter contained in these materials without considering appropriate professional advice. The presenters expressly disclaim all liability in respect of anything done or omitted to be done wholly or partly in reliance upon the contents of these materials. September 25, 2017

2 Tax Planning Using Private Corporations - July 18, 2017: Analysis and Discussion with Finance Ottawa, ON INCOME SPLITTING BACKGROUND AND HISTORY Speaker name: David Christian Company: Thorsteinssons, LLP Disclaimer: This material is for educational purposes only and is not intended to be advice on any particular matter. No one should act on the basis of any matter contained in these materials without considering appropriate professional advice. The presenters expressly disclaim all liability in respect of anything done or omitted to be done wholly or partly in reliance upon the contents of these materials.

3 INCOME SPLITTING - BACKGROUND There is no general policy in the Income Tax Act (Canada) that prevents income splitting Neuman v. The Queen, 98 DTC 6297 (SCC) However, the Income Tax Act (Canada) has always contained antiavoidance rules relating to income splitting Taxation of Private Corporation Policy Conference

4 Income War Tax Act INCOME SPLITTING - BACKGROUND No specifically defined attribution rules. Subsection 4(4) read: A person who, after the first day of August, 1917, has reduced his income by the transfer or assignment of any real or personal, movable or immovable property, to such person's wife or husband, as the case may be, or to any member of the family of such person, shall, nevertheless, be liable to be taxed as if such transfer or assignment had not been made, unless the Minister is satisfied that such transfer or assignment was not made for the purpose of evading the taxes imposed under this Act or any part thereof Taxation of Private Corporation Policy Conference

5 INCOME SPLITTING - BACKGROUND By the time of tax reform in 1970, the rules had evolved into a more familiar form: Attribution of income from property transferred to a spouse or to a person under 19 Both attribution rules applied while transferor alive and resident in Canada No attribution of business income, income from loaned property, or secondgeneration income Taxation of Private Corporation Policy Conference

6 INCOME SPLITTING - BACKGROUND Denial of deduction of salary paid by a spouse to a spouse (no inclusion to recipient, so no double taxation) Similar rule for remuneration by a partnership in which a spouse is a partner Rule that gave discretion to Minister to allocate income of a spousal partnership to one spouse alone Attribution rule for transfer of rights to income Taxation of Private Corporation Policy Conference

7 INCOME SPLITTING - BACKGROUND Post-tax reform: the modern attribution rules take shape: Attribution of income and gains from property transferred to spouse Retention of rules on remuneration of spouses, including partnerships (later replaced by subsection 103(1.1)) Attribution of income from property transferred to spouse Taxation of Private Corporation Policy Conference

8 INCOME SPLITTING - BACKGROUND Attribution of income, but not gains, from property transferred to a person under 18 No attribution of business income, income from loaned property, or secondgeneration income No corporate attribution passive income can be split by transfer to a corporation in which spouse or minor holds a share interest Transfers of rights to income taxable: see subsections 56(2) and (4) Taxation of Private Corporation Policy Conference

9 INCOME SPLITTING - BACKGROUND Expansion of the attribution rules 1985 Budget [Income splitting] was easy, efficient, and anomalous...what was a tolerated tax-planning device soon became an industry, and like all other tax-planning industries, it became a perceived menace to the Department of Finance that had to be erased.as seems to be the case recently with so many legislative amendments that try to erase a simple planning technique, the amendments introduced complexities and difficulties that far outweighed the menace they were intended to cure. Samuel Minzberg, 1986 CTF National Tax Conference Taxation of Private Corporation Policy Conference

10 INCOME SPLITTING - BACKGROUND After the 1985 Federal Budget the modern form of the attribution rules is introduced: Attribution of income and gains from property transferred to spouses, and of income from property transferred to minor children and nieces and nephews Specific trust attribution rules The introduction of the corporate attribution rule Attribution of income from loaned property unless a commercial rate of interest paid No attribution of business income or second-generation income Taxation of Private Corporation Policy Conference

11 INCOME SPLITTING - BACKGROUND The effect of subsection 56(2) The Minister of National Revenue attempted to apply subsection 56(2) of the Income Tax Act (Canada) to discretionary dividends paid on shares Result was the McClurg and Neuman cases at the Supreme Court of Canada, which found subsection 56(2) did not apply to dividends, regardless of contribution - or lack of it by the shareholder receiving the dividend Taxation of Private Corporation Policy Conference

12 INCOME SPLITTING - BACKGROUND Reaction to Neuman: the kiddie tax Commencing in 2000, section imposed an effective prohibition on splitting income with minors by imposing the top marginal tax rate on split income received by the minor. The kiddie tax broke with prior models by taxing split income at the top marginal rate to the recipient, and making a parent jointly and severally liable with the minor for the tax, rather than attributing the income to where it was supposed to go Effect of kiddie tax: eliminate incentive to split income with minors Taxation of Private Corporation Policy Conference

13 INCOME SPLITTING - BACKGROUND Later developments: Pension income splitting permitted for 2013 and subsequent years The family tax cut, which permitted splitting of income by all taxpayers, implemented for 2014, was repealed after 2015 by the new government Taxation of Private Corporation Policy Conference

14 Tax Planning Using Private Corporations - July 18, 2017: Analysis and Discussion with Finance Ottawa, ON CCPCs and Income Sprinkling: (Some of) the Numbers To edit your Header/Footer select <View> <Slide Master> (Delete this box) Disclaimer: This material is for educational purposes only and is not intended to be advice on any particular matter. No one should act on the basis of any matter contained in these materials without considering appropriate professional advice. The presenters expressly disclaim all liability in respect of anything done or omitted to be done wholly or partly in reliance upon the contents of these materials. Speaker name: Michael Wolfson Company: University of Ottawa

15 Acknowledgements Social Sciences and Humanities Research Council -- funding Statistics Canada data assembly and front-line analysis Neil Brooks, Mike Veall, Scott Legree, Brian Murphy co-authors Canadian Tax Journal editorial and peer review Disclaimer my own views; full responsibility rests with Michael Wolfson Taxation of Private Corporation Policy Conference

16 How the Empirical Analysis Was Done T1s Individuals & Families Full Income etc. T2S50 Share Owners T4s T5s Increment in Retained Earnings Taxation of Private Corporation Policy Conference T2s & GIFIs for CCPCs all data linked and analyzed within Statistics Canada s secure environment challenging record linkages GIFI data calendarized unable to link trusts no data on share ownerships < 10%, nor on voting control only family members living at same address under-estimates re sprinkling?

17 Percentage of filers with over 10% ownership shares in at least one CCPC, 2001 to 2011, by total T1 income deciles and top groups Taxation of Private Corporation Policy Conference Decile 1 < 5,800 Decile 2 < 11,900 Decile 3 < 16,900 Decile 4 < 21,700 Decile 5 < 27,500 Decile 6 < 34,100 Decile 7 < 41,500 Decile 8 < 51,600 Decile 9 < 68,800 P90-95 < 86,700 P95-99 < 163,300 Next 0.9 < 577,000 Next 0.09 < 2,305,700 Top ,305,700

18 Number of CCPCs directly owned by owners, by total T1 income group, 2011 Decile 1 < 5,800 Decile 2 < 11,900 Decile 3 < 16,900 Decile 4 < 21,700 Decile 5 < 27,500 Decile 6 < 34,100 Decile 7 < 41,500 Decile 8 < 51,600 Decile 9 < 68,800 P90-95 < 86,700 P95-99 < 163,300 Next 0.9 < 577,000 Next 0.09 < 2,305, Taxation of Private Corporation Policy Conference Top ,305,700

19 Complexity of CCPC ownership: Maximum number of levels of ownership, by total T1 income group, Taxation of Private Corporation Policy Conference Decile 1 < 5,800 Decile 2 < 11,900 Decile 3 < 16,900 Decile 4 < 21,700 Decile 5 < 27,500 Decile 6 < 34,100 Decile 7 < 41,500 Decile 8 < 51,600 Decile 9 < 68,800 P90-95 < 86,700 P95-99 < 163,300 Next 0.9 < 577,000 Next 0.09 < 2,305,700 Top ,305,700

20 Trend Effects of Including CCPC Undistributed Income in the Measurement of Income Inequality Taxation of Private Corporation Policy Conference

21 Average Amounts of Directly Owned CCPC Income by (After- Tax + Capital Gains + Direct CCPC) Income Quantile, Taxation of Private Corporation Policy Conference

22 Income Sprinkling: Widely Disseminated Advice Small business owners who employ family members for income-sharing purposes need to pay a reasonable salary, and be able to show the paperwork behind the pay. But what s reasonable?...unfortunately, the CRA doesn t have a hard and fast rule for what s deemed an acceptable salary. But if you pay the family member what you would pay a typical employee, the CRA would have little reason to discount the deduction. To determine a realistic wage isn t difficult, though. Career websites list average wages for jobs in numerous industries. According to the federal government s Job Bank site, the median hourly wage for an office clerk is $18 an hour, for instance, although the site indicates you could go as high as $28 and still be in the right ballpark. Kira Vermond, One Way To Reduce Small-Business Taxes: Income-Splitting, Globe and Mail, Monday, May 4, 2015 ( Taxation of Private Corporation Policy Conference

23 Taxation of Private Corporation Policy Conference

24 quote from 2005 ON budget Taxation of Private Corporation Policy Conference (page 159)

25 Numbers of CCPCs by Industrial Classification Restaurants Lawyers Doctors Taxation of Private Corporation Policy Conference

26 Spring 2015 Report 3 on Tax-Based Expenditures 3.47 Evaluation requirements for direct program spending. Direct program spending is subject to. (evaluation) over a five-year cycle. The policy defines evaluation as the systematic collection and analysis of evidence on the outcomes of programs to make judgments about their relevance, performance, and alternative ways to deliver them or to achieve the same results Evaluation requirements for tax-based expenditures. the policy requirement to evaluate programs does not apply to tax-based expenditures Conclusion overall we concluded that the Department fell short on managing tax-based expenditures. We reached this conclusion because these expenditures were not systematically evaluated and the information reported did not adequately support parliamentary oversight Taxation of Private Corporation Policy Conference

27 Incomes of Individuals Working in the Offices of Doctors Numbers of Doctors by Individual Income and Ownership of a Private Company Income ($000s) Reported on Individual Income Tax Returns $100-$200 $200-$350 $350-$500 > $500 > $100 Does not Own a CCPC 10,050 8,120 2, ,880 Owns a CCPC 18,300 8,110 2,480 1,390 30,280 Totals 28,350 16,230 5,230 2,350 52,160 Average Family Incomes ($000s) of Doctors and Their Immediate Families Plus Income Retained in a CCPC Income ($000s) Reported on Individual Income Tax Returns $100-$200 $200-$350 $350-$500 > $500 Does not Own a CCPC Owns a CCPC , Taxation of Private Corporation Policy Conference n.b. these incomes are after subtracting salaries and office expenses paid by the Offices, both CCPCs and self-employed there were over 7,500 doctors in 2011 receiving more that $350,000 on their T1s doctors owning CCPCs had much more total family income not yet known how much was from sprinkling

28 For the first $1,996 of private income, benefits reduce at 100% (50% for regular GIS + 50% for GAINS). This is the same as before. Between $1,996 and $4,600 of private income, GIS benefits reduce at its regular rate of 50% (GAINS is gone and the new top up hasn t begun to reduce) Between $4,600 and $8,400 in private income, GIS benefits reduce at a rate of roughly 92% (50% for the regular GIS benefit + 42% for the increased GIS top-up which reduces within this zone) After $8,400 of private income, GIS benefits again reduce at a rate of 50% (The top-up is completely gone) Compare Effective Income Tax Rates for Low Income Seniors, the Poverty Trap Taxation of Private Corporation Policy Conference from 50 to 100% (and higher)

29 Concluding Comments first time: shining a statistical light into a dark corner of Canada s income tax this kind of analysis is not easy, but as concluded by the AG, it needs to be done, done well, and made available to Parliament and the public on a regular basis CCPCs are widely used especially among those with the highest incomes income sprinkling appears to involve a significant (individual + corporate) income tax revenue cost, possibly on the order of at least $500 million per year it is horizontally inequitable = unfair it induces an important non-neutrality in the tax system, thereby encouraging nonproductive tax planning costs in addition to its revenue costs while powerful vested interests complain loudly about having to pay tax at top rates as high as 50%, hundreds of thousands of Canada s seniors face much higher effective income tax rates, and no one seems to care Taxation of Private Corporation Policy Conference

30 Tax Planning Using Private Corporations - July 18, 2017: Analysis and Discussion with Finance Ottawa, ON Income Splitting Technical Summary of Proposed Legislation To edit your Header/Footer select <View> <Slide Master> Speaker name: Rachel Gervais Company: BDO Canada LLP (Delete this box) Disclaimer: This material is for educational purposes only and is not intended to be advice on any particular matter. No one should act on the basis of any matter contained in these materials without considering appropriate professional advice. The presenters expressly disclaim all liability in respect of anything done or omitted to be done wholly or partly in reliance upon the contents of these materials.

31 Tax on Split Income (TOSI) Applies by virtue of S.120.4(2) Specified Individual * will be subject to the top personal tax rate for the year on the individual s Split Income * for the year Proposals extend rules to apply to all Canadian resident individuals who included in income certain amounts that are derived from a business that is, or was, sufficiently linked to a related individual who is resident in Canada Proposals apply to minors and adult family members To apply the new rules, must consider new or modified definitions, new reasonableness tests for certain types of income of individuals 18 years of age and older, and anti-avoidance rules * Revised definitions under S (1) of the Act Taxation of Private Corporation Policy Conference

32 Revised Definition of Specified Individual S (1) Age Current TOSI Proposed TOSI Under age 18 (minor) Age 18 or older (adult) Canadian resident throughout the year Parent resident in Canada at any time during the year At no time in the year was a non-resident Not applicable Canadian resident at end of the year* At any time during the year either: Parent resides in Canada, or A related individual resides in Canada, and the minor receives certain income derived from a business of that related individual Canadian resident at end of the year* At any time during the year a related individual resides in Canada, and the adult receives certain income derived from a business of that related individual. * Where individual dies in the year, Canadian resident immediately before death Note: for purposes of the proposed rules, related person is extended to include aunts, uncles, nieces or nephews Taxation of Private Corporation Policy Conference

33 New definition of Connected Individual S.120.4(1) Sets out factors applicable when considering the degree of connectivity between an individual and a corporation relevant for: Definition of specified individual in determining whether a business is sufficiently linked to a related individual, when looking at whether income is derived from that business Definitions of split income (income from indebtedness under para. (d) of the definition of split income), related source, and split portion (i.e. for the purposes of applying the reasonableness test under Subparagraph (b)(ii) of the definition of split portion) A connected individual in respect of a corporation includes an individual resident in Canada who can be shown to meet any of the following conditions set out in paragraphs (a) through (d) of the definition: a) Strategic influence b) Equity influence c) Earnings influence d) Investment influence Taxation of Private Corporation Policy Conference

34 Specified Individual - Example Facts: Mr. and Mrs. X X Corp. incorporated in Upon incorporation, Mr. and Mrs. X each subscribed for 50% of the common shares of X Corp for a nominal amount. Mr. X was never active in the business and worked part-time for another employer while spending a significant amount of time caring for their child X Jr. Mrs. X ran the business and its value grew considerably X Jr. became involved in the business and by 2016, was running the business by himself. In early 2016, the X family undertook a standard freeze for X. Corp Mr. and Mrs. X each exchanged their common shares for fixed value, redeemable and retractable preferred shares with an aggregate redemption value of $4M. X Jr. subscribed for all the newly issued common shares of X Corp. for a nominal amount Plan was for each of Mr. and Mrs. X to receive approximately $100K of dividends annually by way of share redemptions of their preferred shares throughout retirement Standard Wasting Freeze This $200K would represent the majority of Mr. and Mrs. X s annual retirement income. They will also receive Canada Pension Plan payments Taxation of Private Corporation Policy Conference

35 Specified Individual - Example Analysis under proposed TOSI rules: Both Mr. and Mrs. X will be Specified Individuals Related individual (X Jr.) resides in Canada and Mr. and Mrs. X receive income (dividends) derived from a business carried on by corporation of which X Jr. is a specified shareholder.* All dividends received by way of share redemption by Mr. and Mrs. X may be subject to TOSI Mr. X Clearly subject to TOSI on dividends as he was never active in the business at all Mrs. X Possibly subject to TOSI on dividends Will depend on reasonableness test discussed later i.e. What is reasonable given Mrs. X s past contributions to X Corp and past compensation prior to retirement? * X Jr. would also meet the criteria outlined in the proposed new definition of connected individual contained in S.120.4(1) which may be relevant if the fact pattern was different and X. Jr was not a specified shareholder as defined in S. 248(1) Taxation of Private Corporation Policy Conference

36 Specified Individual Discussion of Example Becoming specified individuals will reduce Mr. and Mrs. X s retirement income significantly Planning was implemented assuming marginal rates on share redemption dividends. Now potentially subject to highest marginal rate on every dollar received Retroactive Taxation? - $4M of preferred share value accumulated prior to Appropriate to now tax all that value at highest marginal rates? How will X Corp s cash flow be impacted? Will now require significantly more cash to give Mr. and Mrs. X equivalent amounts of retirement income as planned. How much time and money will X Corp./X family need to spend to justify reasonableness of Mrs. X s dividends? How much money did she draw in the past? What happens on death if Mr. and Mrs. X pass away with unredeemed preferred shares outstanding? Could entire remaining value be taxed at dividend rates? See proposed S.120.4(4) More facts would be required to answer this question Taxation of Private Corporation Policy Conference

37 Revised Definition of Split Income S (1) Category Current TOSI Proposed TOSI Private company taxable dividends, S.15 shareholder benefits Paragraph (a) Paragraph (a) no change Business income from a partnership Paragraph (b) Paragraph (b) change for related source definition Business income from a trust Paragraph (c) Paragraph (c) change for related source definition Income from indebtedness Not applicable Paragraph (d) new Taxable capital gains and income from the disposition of certain property Not applicable Paragraph (e) new Section 246 amounts (conferred benefits) Not applicable Paragraph (f) new Reinvested split income, income subject to the attribution rules and capital dividends where certain conditions met (for individuals under the age of 25) Not applicable Paragraph (g) - new Taxation of Private Corporation Policy Conference

38 New Definition Split Portion S (1) For a specified individual who is 18 years of age or older, it will generally be necessary to determine if there is a split portion of the amount of their split income. Only the split portion will be subject to TOSI (subject to the antiavoidance rule under S (1.1)(d)) Category of split income Paragraph of the definition Reasonableness Test Amounts under paragraph (g) of split income of individuals under the age of 25 All amounts of split income, except those covered in paragraphs (e) and (g) of that definition Amounts under paragraph (e) of split income taxable capital gains and income from the disposition of certain property Paragraph (a) Paragraph (b) Paragraph (c) No Yes* Yes** * Based on contribution factors (arm s length view) and what has been paid/payable. Must also consider anti-avoidance rules, restriction rules for 18 24, deeming rule for inherited property (S.120.4(1.1)(e)(ii) and (iii)) ** Test requires consideration of whether certain income from the property would be considered split income Taxation of Private Corporation Policy Conference

39 Example Split Income Paragraph (e) Facts Mr. A owns 60% of the common shares of A. Corp. He runs the business independently The other 40% of the common shares are owned by Mr. A s uncle (age 50) who contributed $40,000 to subscribe for share capital when A. Corp was incorporated. There was no intention to income split with Mr. A s uncle, he was simply a source of start-up capital. Mr. A s uncle is not (and never was) involved in the management of the business The shares of A. Corp are being sold by the current shareholders after 2017 to arm s length purchasers. A capital gain will be realized upon sale by each of the current shareholders. None of the shareholders have ever received any dividends on the common shares Taxation of Private Corporation Policy Conference

40 Example Split Income Paragraph (e) Is Uncle s gain on the disposition of shares subject to TOSI? Uncle is a specified individual in respect of A. Corp s business Resident in Canada Related to Mr. A (Proposed S (1.1) uncles and nephews are related) Business of A. Corp is carried on by Mr. A. and Mr. A is a specified shareholder* of A. Corp. Uncle s gain on the disposition is included in Paragraph (e) of the definition of split income Uncle is a specified individual Uncle has a taxable capital gain from the disposition of property The property is a share of the capital stock of a corporation which is not a public company or mutual fund corporation Would paragraph (c) of the split portion definition exclude this gain from TOSI? Appears as though we would need to determine if the capital gain would have been included in split income had it been received as an amount included in Paragraphs (a) (d) of the definition of split income (i.e. as a dividend, business income or income from indebtedness) How can we answer this? Does the reasonableness test apply? If so, what would be reasonable given Uncle s original $40,000 contribution? * Also a connected individual however not relevant given particular fact pattern Taxation of Private Corporation Policy Conference

41 Split Income Paragraph (e) Discussion of Example If the gain is subject to TOSI: Why should Uncle s gain be treated differently than that of an arm s length investor? He was simply a source of start-up financing who happened to be Mr. A s Uncle No income splitting intention What if Uncle wanted to claim LCGE on his gain realized? No longer available under proposed rules to constrain LCGE multiplication* What if Mr. A. wanted to increase his interest in the company and purchase his Uncle s shares? If gain subject to TOSI, would gain be taxed at dividend rates? If proposed Section 120.4(4) applies, gain would be taxed as a non-eligible dividend * Assumes no election made to crystallize LCGE under proposed S (18) Taxation of Private Corporation Policy Conference

42 Constraining the Capital Gains Exemption Background The government is particularly concerned that the current LCGE rules can be used to multiply the LCGE so that it is available to family members who are not involved in the business The government: views that these individuals may not have effectively contributed to the business; is also concerned about the use of family trusts, primarily those that are discretionary, to allocate capital gains and income among family members Taxation of Private Corporation Policy Conference

43 Constraining the Capital Gains Exemption New Restrictions on Minors Proposed age limit so that minors will no longer qualify for the LCGE in respect of capital gains that are realized, or that accrue LCGE will no longer be available to minors regardless of whether the child is involved in the business If minor acquires qualifying property and disposes of it when they are an adult, the increase in the value of the property during the time the individual was a minor will not be eligible for the LCGE It may be necessary to have a valuation of the shares completed at the beginning of the taxation year in which the minor turns 18 years old Taxation of Private Corporation Policy Conference

44 Constraining the Capital Gains Exemption Tying the use of the LCGE to the new TOSI Rules Proposals provide that the LCGE will generally not apply if the taxable capital gain arising from a disposition is included in an individual s split income If an amount is not included in TOSI only because the recipient of the income is already taxed at the top marginal tax rate, restriction on LCGE can apply If a taxable capital gain (TCG) from the disposition of a property is included in individual s split income, then the amount that the individual can deduct under the LCGE in computing the TCG is reduced by 2 times the amount of the TCG included in computing the individual s split income Taxation of Private Corporation Policy Conference

45 Constraining the Capital Gains Exemption How Property in Trusts is Affected New limits for beneficiaries of a trust from claiming any LCGE on dispositions In order for an associated gain from property held by a trust to be eligible for the LCGE, it must be designated by an Eligible LCGE Trust An Eligible LCGE Trust includes: A spousal or common-law partner trust or alter ego trust where the individual claiming the LCGE is the trust s principal beneficiary; Certain employee share ownership trusts, where the individual beneficiary is an arm s length employee of the employer sponsor of the arrangement Taxation of Private Corporation Policy Conference

46 Constraining the Capital Gains Exemption How Property in Trusts is Affected Trust measures would apply in situations where the trust realizes a capital gain and allocates it to a beneficiary, and also where the trust elects to transfer the property with an accrued gain to a beneficiary who realizes the gain at a later date on a disposition These measures would not prevent trusts that are currently eligible to undertake rollovers to beneficiaries from continuing to do so; however, unless an exception applies, no deduction would be allowed under the LCGE in respect of the capital gain that is transferred from a trust on a rollover of property to a beneficiary Taxation of Private Corporation Policy Conference

47 Constraining the Capital Gains Exemption Election for Deemed Disposition in 2018 Transitional rules provide for grandfathering of certain dispositions that occur in 2018, allowing an individual to elect to realize in 2018, a capital gain in respect of eligible property by way of a deemed disposition for proceeds up to the FMV of the property Transitional rules provide an opportunity for property that currently does not qualify for the capital gains exemption in 2017 to be purified as proposed legislation will reduce the holding period from 24 months to 12 months This means that the purification process must happen before December 31, 2017 in order for the crystallization to occur in Taxation of Private Corporation Policy Conference

48 Panel Discussion Taxation of Private Corporation Policy Conference