Handbook

The course builds on the knowledge and skills you developed in TABL5582 Taxation of Business Entities and focuses specifically on the corporation.  It covers both private and public companies.

This course is designed to help you develop a deep and nuanced understanding of the key issues relating to the income tax treatment of corporations.  The course begins by looking in detail at the rules for the carry forward of company losses and the debt / equity classification.  It then considers more complex dimensions of the distribution concept including the treatment of non-share dividends and bonus shares; the rules relating to capital streaming; tainted share capital accounts; deemed dividends; dividend stripping and liquidator's distributions.  The course then turns to capital profits and the capital gains tax rules that apply to shares, roll-over relief and specific aspects of the value shifting rules.  The course concludes by looking at the consolidation rules and how they interact with other tax rules.

In this course, you will critically analyse legislation, case law and the Commissioner's rulings, but we will discuss real life examples and the policy rationale that underlies the rules.  You will be assessed on a combination of your participation in an allocated class; a problem-style assignment (which will be available at the start of the trimester) and an open book exam containing several problem-style questions.