Volume 2 of Fundamentals of Canadian Income Tax picks up from where Volume 1 left off, and examines the fundamental principles of corporate income tax law. This volume introduces students to the income tax implications of corporate, commercial, and family transactions. As with its companion piece, Volume 1, we use a building block approach, starting with basic and fundamental legal principles of alternative business structures and their income tax effects.
We look at the underlying policies and structure for the income taxation of corporations and shareholders, financing arrangements for equity and debt capital, the use of professional corporations, the taxation of business and investment income of private corporations, shareholder compensation, and corporate distributions to shareholders. In addition, we examine the nature of corporate reorganizations, tax-deferred rollovers, and non-arm’s length share transfers, amalgamations, winding-up, the taxation of non-residents, transfer pricing, and selected aspects of estate planning.
The text is current to January 1, 2018 and incorporates changes announced by the Minister of Finance, but which will be enacted into law later in 2018. It also contains a comprehensive glossary of tax and financial terms, which will be useful for students, and practitioners in commercial practices.
About the Author:
Vern Krishna joined Faculty of Common Law in 1981 and teaches taxation, business law and corporate finance. Krishna is a graduate (B.Com.) of the University of Manchester (UK) in economics and business; he holds an M.B.A. and LL.B. from the University of Alberta; and he obtained an LL.M. from Harvard University and a Diploma in Comparative Law from Cambridge University in the United Kingdom. He is a member of the Ontario Bar and is Of Counsel, Borden Ladner Gervais LLP. Krishna is a member of the Order of Canada (2004). He was appointed Queen’s Counsel (1989) by the Government of Canada, elected a Fellow of the Royal Society of Canada (1992), and a Fellow of the Certified General Accountants of Canada (1989). He received a LL.D. from the Law Society of Upper Canada in 2004 and the 125th Canada Medal (1993) from the Governor General of Canada. Krishna has been active in both of his professions – law and accounting. He has been a Bencher of the Law Society of Upper Canada since 1990 and served as its elected head [Treasurer] from 2001 to 2003. He was elected President of the Certified General Accountants Association of Ontario in 1995. Krishna is the author of twelve texts in tax, international tax, and business law (see sidebar "Books") and numerous articles and case comments. His writings are frequently cited by the Supreme Court of Canada (see below). He served as a Commissioner on the Ontario Securities Commission from 1995 to 1998 and was a Visiting Scholar in International Tax at Harvard Law School from 1998 to 1999.