Detailed Table of Contents
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1 Detailed Table of Contents CHAPTER1 FIRSTPRINCIPLESANDBEST PRACTICES 1.1 The Art of Reading the Income Tax Act... 4 (a) General Structure of the Income Tax Act... 4 (b) Specific Provisions of the Act... 5 (c) Backing Into the Income Tax Act... 7 (d) Secondary Sources for Understanding the Income Tax Act (e) Additional Considerations in Reading the Income Tax Act (i) Preambles (ii) Turns of Phrase (iii) Defined Terms (iv) Pro-rations (v) Formulae Interpreting the Income Tax Act (a) Tax Law as an Accessory System (b) Other Sources of Law (c) Statutory Construction and the Income Tax Act (i) The Rule of Strict Construction (ii) Stubart and the Rejection of Strict Construction (iii) The Modern Rule and the Legacy of Stubart (iv) Current State of the Law Concluding Remarks Review Questions CHAPTER2 PARTNERSHIPINCOME 2.1 Nature of a Partnership (a) Between Persons (i) Tiered Partnership Structures (ii) Can a Trust be a Partner? (b) A Business (c) With a View to Profit (d) Foreign Law Partnership a Person for Income Computation Purposes (a) Introduction (b) Taxpayer (c) Person (d) Individual Fictions Created by Subsection 96(1) (a) Partnership a Separate Person 96(1)(a) xix
2 Taxation of Corporations, Partnerships and Trusts (b) Taxation Year a Fiscal Period 96(1)(b) (c) Each Activity Carried on by Partnership as a Separate Person 96(1)(c) (d) Miscellaneous 96(1)(d), (e) and (e.1) (e) Flow-through of Source to Partner 96(1)(f) and (g) Example Subsection 96(1) Preferential Allocations of Partnership Income/Loss Example Subsection 96(1) Example Subsection 96(1) Payments to a Retired Partner (a) Effect of Withdrawal at Law (b) Allocation of Partnership Income to a Retired Partner under Subsection 96(1.1) (c) Treatment of Payments to a Retired Partner if Subsection 96(1.1) Not Applicable Attribution 96(1.8) At-Risk Rules (a) Partnership Losses versus Partnership Liabilities (b) At-Risk Rules Anti-Avoidance Section Concluding Remarks Review Questions CHAPTER3 CONTRIBUTIONSTO/DISTRIBUTIONS FROM A PARTNERSHIP 3.1 Nature of a Partnership Interest Transfers of Property to or from a Partnership 97(1) and 98(2) Example Subsection 98(2) Transfers of Property to a Partnership under Subsection 97(2) (a) Overview (b) Elected Amount 85(1)(a) as Modified for Partnerships (c) Elected Amount 85(1)(b) as Modified for Partnerships Example Subsection 97(2) (d) Elected Amount 85(1)(c) as Modified for Partnerships Example (1)(c) as Modified by 97(2)(a) (e) Loss Limitation Rules as Modified for Partnerships (f) Benefit Conferred on Related Person 85(1)(e.2) as Modified for Partnerships Example Paragraph 85(1)(e.2) as Modified for Partnerships (g) Paragraph 85(1)(e.3) as Modified for Partnerships (h) Cost of Boot 85(1)(f) as Modified for Partnerships xx
3 Table of Contents (i) Adjustments to Cost of Partnership Interest 97(2)(b) Example Paragraphs 85(1)(f) and 97(2)(b) Adjusted Cost Base of a Partnership Interest (a) Deemed Gain 40(3.1) and 40(3.11) (b) Adjustments in Computation of Adjusted Cost Base of Partnership Interest Example Cost Adjustments under Paragraph 53(1)(e) Example Adjustments under Section Partner Withdrawal/Partnership Dissolution (a) Time of Partnership Dissolution (b) Income Tax Implications of Partnership Dissolution or Partner Withdrawal (c) Subsection 98(1) Partnership Dissolution Tax-Deferred Partnership Dissolutions (a) Conversion of a Partnership to a Co-ownership or Proprietorship Example Subsection 98(3) (b) Incorporation of a Partnership (c) Replacement of Partnership Elections Concluding Remarks Review Questions CHAPTER 4 TRUST INCOME 4.1 Introduction Meaning of Trust Graduated Rate Estate Regime Trust a Taxpayer Trust Income Payable to a Beneficiary Taxation of Beneficiary Trust Income Payable to a Beneficiary Taxation of Trust Income Deemed not Paid Subsection 104(13.1) and (13.2) Designations Source and Character of Trust Income (a) General Rule (b) Dividends from Taxable Canadian Corporations (c) Net Taxable Capital Gains (d) Non-taxable Dividends (e) Trust Benefits Year Deemed Disposition Rule (a) Introduction (b) Pre-1972 Spousal Trusts, Post-1971 Partner Trusts, Joint Partner Trusts, Alter-Ego Trusts & Self-Benefit Trusts Anti-Avoidance xxi
4 Taxation of Corporations, Partnerships and Trusts 4.11 Concluding Remarks CHAPTER 5 CONTRIBUTIONS TO/DISTRIBUTIONS FROM A TRUST 5.1 Introduction Classification of Trusts (a) Personal Trusts (b) Unit Trusts (c) Employment-related Benefit Trusts Contributions of Property to a Trust (a) Default Scheme (b) Exceptions to Default Scheme (i) Qualifying Transfer (ii) Qualifying Disposition Disposition of Trust s Interests Income Interests (a) Cost of Income Interest (b) Disposition of Income Interest Capital Interests (a) Capital Interest Defined (b) Disposition of Capital Interest (c) Cost of Capital Interest (d) Personal Trust or Prescribed Trust Subsection 107(1.1) (e) Trusts Generally Subsection 107(1) (f) Distributions In Satisfaction of Capital Interest Example Example Concluding Remarks Review Questions CHAPTER 6 CONTROL AND CLASSIFICATION OF CORPORATIONS AND INCOME 6.1 Introduction Classification of Income Corporate Residence (a) Common Law Residence (b) Deemed Residence under the Act Concepts of Control (a) De Jure Control (i) Shares Held by a Corporation (ii) Shares Held by a Trust (iii) Shares Held by a Partnership xxii
5 Table of Contents (iv) Other Issues (b) De Facto Control (c) Deemed Control Classification of Corporations (a) Private Corporation (b) Public Corporation (c) Canadian Corporation (d) Canadian-controlled Private Corporation Corporate Rates of Tax (a) Basic Federal Rate (b) Provincial Abatement (c) General Rate Reduction (d) Additional Refundable Tax (e) Small Business Deduction Concluding Remarks Review Questions CHAPTER7 ARM SLENGTHDEALINGS, AFFILIATED PERSONS, ASSOCIATED CORPORATIONS AND THE SMALL BUSINESS DEDUCTION 7.1 Introduction Arm s Length Dealings Related Persons Example Subsection 251(2) Affiliated Persons (a) Definition of Affiliated Persons (b) Superficial Loss (c) Subsections 40(3.3) to (3.6) (d) Stop-Loss System in Section Associated Corporations (a) Specified Class (b) Deeming Rules for Association Purposes Example Paragraph 256(1.2)(c) The Small Business Deduction (a) Introduction (b) Income of the Corporation for the Year from an Active Business (c) Active Business Carried on by a Corporation (d) Specified Investment Business (e) Personal Services Business (f) Specified Partnership Income (g) Taxable Income Exempt from Federal Tax Example Paragraph 125(1)(b) xxiii
6 Taxation of Corporations, Partnerships and Trusts (h) Business Limit Concluding Remarks Review Questions CHAPTER 8 TAXATION OF CORPORATE DISTRIBUTIONS AND APPROPRIATIONS 8.1 Corporate Distributions (a) Overview Example Integration (b) Dividends in Kind (c) Stock Dividends (d) Paid-up Capital Example Paid-up Capital Subsection 89(1) (e) Capital Dividends Deemed Dividends (a) Overview (b) Paid-up Capital Reductions (c) Purchase for Cancellation or Redemption of Shares (d) Winding-up Distributions (e) Dispositions on a Purchase, Redemption or Cancellation of Shares Example Gain Realized on Redemption of Shares (f) Paid-up Capital Increases (g) Miscellaneous Provisions in Section Shareholder Benefits Shareholder Debt Concluding Remarks Review Questions CHAPTER9 INTEGRATION OF CORPORATION AND SHAREHOLDER TAXES 9.1 Introduction Dividend Gross-up and Tax Credit Example Example of integration assuming a 20% corporate tax rate and a 30% individual tax rate Example Integration Example Passive Income Example Integration Example Active Business Income Small Business Deduction Example Integration Example Active Business Income General Corporate Rate Refundable Tax (a) Refundable Tax on Aggregate Investment Income of a CCPC xxiv
7 Table of Contents (b) Refundable Dividend Tax on Hand Example Refundable Dividend Tax on Hand (c) Part IV Tax Example Part IV Tax (d) Dividend Refund Review Questions CHAPTER 10 DIVIDEND (SURPLUS) STRIPPING 10.1 Introduction Pre-1972 Tax Reform Post-1972 Tax Reform Example Section Post-General Anti-avoidance Rule Provisions that Limit Paid-up Capital Increases Example Subsection 85(2.1) Example Paragraph 85(2.1)(b) Concluding Remarks Review Questions CHAPTER 11 CAPITAL GAINS STRIPPING 11.1 Introduction The Incentive to Capital Gains Strip History of Section Subsection 55(2) Dissected First Condition Second Condition Third Condition [First Alternative] Third Condition [Second Alternative] Third Condition [Third Alternative] Fourth Condition Fifth Condition Safe Income Related Issues (a) Income Earned or Realized (b) Safe Income On Hand (c) Safe Income Determination Time (d) Consolidated Approach (e) Allocation of Safe Income Supporting Provisions Concluding Remarks Review Questions xxv
8 Taxation of Corporations, Partnerships and Trusts CHAPTER 12 TAX DEFERRED TRANSFERS/EXCHANGES/ CONVERSIONS 12.1 Introduction Price Adjustment Clauses Types of Property and their Respective Cost Amounts (a) Tax Value versus Book Value (b) Non-depreciable Capital Property or Inventory (c) Depreciable Property Transfers of Property to a Corporation under Section (a) Conditions of Rollover (b) Property Eligible for Rollover (c) Elected Amount (d) Significance of Elected Amount Example Paragraphs 85(1)(f), (g) and (h) (e) Adjustments to Elected Amount Example Paragraph 85(1)(e.2) (f) Late-filed and Amended Elections (g) Intersection of Federal and Provincial Elective Provisions and Inter-Provincial Tax Avoidance Share for Share Exchange under Section (a) Conditions for Rollover (b) Exclusions from Rollover Conversions/Exchanges under Section 51/ Conversions/Exchanges under Section Concluding Remarks Review Questions CHAPTER 13 AMALGAMATIONS AND WINDINGS-UP 13.1 Introduction (a) Amalgamations (b) Windings-up Qualifying Amalgamations (a) Carry Over of Tax Attributes of Property of a Predecessor Corporation (b) Carry Over of Tax Profiles of Each Predecessor Corporation (c) Shareholder Level Tax Consequences Windings-up (a) Tax Deferred Windings-up Subsection 88(1) (b) Taxable Windings-up Subsections 84(2) and 88(2) Concluding Remarks Review Questions xxvi
9 Table of Contents INDEX xxvii
10
CONTENTS VOLUME II VOLUME I. Detailed contents of Volume II, Chapters 11 to 21 follows. The textbook is published in two Volumes:
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CONTENTS CHAPTER 1. CHAPTER 1, continued CHAPTER 2. Introduction To Federal Taxation In Canada. Income Or Loss From An Office Or Employment.
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