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A corporation is nothing but a piece of paper. And yet, this piece of paper enjoys the status of a person and has an independent identity as a taxpayer (the “separate entity principle”). It can generate tremendous value for its shareholders through tax savings resulted from tax deferral, tax shifting, and tax subsidies. Why does tax law allow such value to exist? Is there any hard line constraining the scope of the tax benefits associated with the corporate form? To what extent can the two pillars (Pillar One and Pillar Two) crush the corporate form? What is the future of corporate form in income taxation? This paper seeks to answer these questions through examining the Canadian income tax system.


"Written for a symposium “Taxing Income and Consumption: Past, Present and Future”, April 11-13, 2023 Coimbra, Portugal"

"Research for this project was supported by a grant from Social Sciences and Humanities Research Council, Canada. The author recognizes the assistance of Shelley Zhang, a JD/MBA student at York University and comments on an earlier draft by Scott Wilkie."