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Corporate Tax

Notes

1 General Corporate Tax Topics

Residency of Corporations
Taxable Canadian Property Defined
Advantages and Disadvantages of Incorporation
Canadian Controlled Private Corporation (CCPC) and Implications
Active Business Income (ABI)
Personal Service Business (PSB) and Specified Investment Business (SIB)
Shareholder Loans – Loans made by corporation to shareholders

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Residency of Corporations
Taxable Canadian Property Defined
Advantages and Disadvantages of Incorporation
Canadian Controlled Private Corporation (CCPC) and Implications
Active Business Income (ABI)
Personal Service Business (PSB) and Specified Investment Business (SIB)
Shareholder Loans – Loans made by corporation to shareholders

Related Corporations and Implications
Affiliated Corporations and Implications
Associated Corporations and Implications

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Related Corporations and Implications
Affiliated Corporations and Implications
Associated Corporations and Implications

2 Division B Income: Income for Tax Purposes

2.1 Business Income Earned by Corporations

Business Income vs. Capital Gains
Income or Loss from a Business
Reserves for Tax Purposes
Capital Cost Allowance for Depreciable Capital Assets
CCA Classes & Rates

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Business Income vs. Capital Gains
Income or Loss from a Business
Reserves for Tax Purposes
Capital Cost Allowance for Depreciable Capital Assets
CCA Classes & Rates

2.2 Property Income Earned by Corporations

Income from Property | Interest, Dividends, Rent, and Royalties

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Income from Property | Interest, Dividends, Rent, and Royalties

2.3 Capital Gains: Corporations

Capital Gains and Losses
Replacement Property Rules
Allowable Business Investment Losses (ABIL)
Disposal of Land and Adjacent Building

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Capital Gains and Losses
Replacement Property Rules
Allowable Business Investment Losses (ABIL)
Disposal of Land and Adjacent Building

3 Taxable Income for Corporations: Division C Deductions

Division C Deductions for Corporations

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Division C Deductions for Corporations

4 TAX PAYABLE FOR CORPORATIONS: DIVISION E

Overview of Federal and Provincial Corporate Tax Rates
Federal Taxes Payable Calculation | Provincial Abatement | Small Business Deduction | Additional Refundable Taxes | M&P Deduction | General Rate Reduction
Refundable Taxes | Part I Refundable Tax | Part IV Refundable Tax | Refundable Dividend Tax on Hand (RDTOH)| Dividend Refund
Scientific Research And Experimental Development (SRED) & Investment Tax Credit (ITC)
Deadlines, Installments, Interest and Penalties

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Overview of Federal and Provincial Corporate Tax Rates
Federal Taxes Payable Calculation | Provincial Abatement | Small Business Deduction | Additional Refundable Taxes | M&P Deduction | General Rate Reduction
Refundable Taxes | Part I Refundable Tax | Part IV Refundable Tax | Refundable Dividend Tax on Hand (RDTOH)| Dividend Refund
Scientific Research And Experimental Development (SRED) & Investment Tax Credit (ITC)
Deadlines, Installments, Interest and Penalties

5 CORPORATE DISTRIBUTIONS - DIVIDENDS

General Rate Income Pool (GRIP) – Canadian Controlled Private Corporation (CCPC)
Lower Rate Income Pool (LRIP) – Non-Canadian Controlled Private Corporation (Non-CCPC)
Capital Dividend Account (CDA)

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General Rate Income Pool (GRIP) – Canadian Controlled Private Corporation (CCPC)
Lower Rate Income Pool (LRIP) – Non-Canadian Controlled Private Corporation (Non-CCPC)
Capital Dividend Account (CDA)

6 CORPORATE REORGANIZATION

6.1 Tax Free Rollovers

Section 85(1) Rollover: Tax Free Rollover to Corporations
Section 85.1 Rollover: Share for Share Exchange
Section 86 Rollover: Exchange of Shares in an Internal Reorganization
Section 87 Rollover: Amalgamations
Section 88(1) Rollover: Winding-up of a Subsidiary
Tax Planning: Vertical Amalgamation vs. Winding-up

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Section 85(1) Rollover: Tax Free Rollover to Corporations
Section 85.1 Rollover: Share for Share Exchange
Section 86 Rollover: Exchange of Shares in an Internal Reorganization
Section 87 Rollover: Amalgamations
Section 88(1) Rollover: Winding-up of a Subsidiary
Tax Planning: Vertical Amalgamation vs. Winding-up

6.2 Other Reorganization Issues

Acquisition of Control (AOC) Rules
Sale of Assets of a Corporation vs. Sale of Shares of the Corporation
Dividend Stripping: Section 84.1
Capital Gains Stripping: Section 55(2)

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Acquisition of Control (AOC) Rules
Sale of Assets of a Corporation vs. Sale of Shares of the Corporation
Dividend Stripping: Section 84.1
Capital Gains Stripping: Section 55(2)

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