The objective of this course is to familiarize the reader with not only the "basics" relative to the income tax provisions affecting Canadian-controlled private corporations (CCPCs), but also to present those provisions that affect practical implementation (planning or compliance) with respect to the core matters. The material is not intended to be exhaustive, but rather illustrative of the areas typically confronted by a CGA in practice.
In a corporate tax discussion or review, the characteristic unique to CCPCs is the concept of integration, where total corporate and personal tax on a given amount of income will approximate the total tax payable had that income been earned personally. That most often the CCPC is simply an extension of the individual is undeniable. Wherever practical, this course takes this integrative approach.
The main concern of the course is the issue of how CCPCs and their owner/managers are taxed on the income first earned by the corporation and subsequently distributed to the shareholders. There are a number of tax incentives by way of tax deferral, tax savings, and income splitting opportunities available to business people who decide to incorporate their active business activities into a CCPC. To fully understand these incentives, it is necessary to become familiar with the various anti-avoidance measures that have been put in place to limit the circumstances to which these incentives apply. This course will review these incentives and limitations, and provide a framework for business people and their advisors to plan the most tax-efficient approach to minimizing the overall tax burden.
This course is based on the Income Tax Act as it stood at July 5, 2011. Any pending legislative amendments, pronouncements, and proposals announced up to then have been incorporated into these materials. Some of the Income Tax Act references included in these materials have, by necessity, been paraphrased. While every effort has been made to retain the integrity and flavour of the Act, you may wish to refer to the specific Act provision to build your comprehension.