Comparative Corporate Tax

Elective

The Comparative Corporate Tax course considers the basic elements of corporate tax systems in a structural setting. The focus is on three artificialities that arise from the nature of a corporation: the artificiality of a corporation as an income deriving entity; the artificiality of a corporation as a source of income in the form of dividends; and the artificiality of shares in corporations as assets separate from the assets held by a corporation. The course focuses on the corporate income tax systems of Australia, Germany, the UK and the US. The course does not deal with generic income tax issues (applicable to both individuals and corporations), such as the calculation of business income.

The course includes the following topics:

• Derivation: identifying corporations, group taxation, tax treatment
• Distribution: debt/equity distinction, hidden profit distributions, dividend relief
• Incorporation, transfer of shares, change of control
• Return of capital, share buy-backs, liquidation
• Bonus shares, convertibles, options, reconstructions, mergers, demergers

The course is taught by Professor Peter Harris, University of Cambridge and Professor John Vella