Faculty Author Type

Current Faculty [David Duff]

Document Type

Working Paper

Publication Date



Tax, Small Business Taxation, Corporate Tax, Taxation of Shareholders, Tax Simplicity, Tax Neutrality


Among the many contributions that Judith Freedman has made to tax law and policy in the United Kingdom and around the world, one of the most sustained and significant involves the regulation and taxation of small business. This article reviews Professor Freedman’s contributions to tax law and policy regarding small business, and evaluates Canadian experience with the taxation of private companies and their shareholders in light of Professor Freedman’s work. Part II summarizes Professor Freedman’s main conclusions regarding the taxation of small business, addressing both the taxation of similar economic activities conducted through different legal forms and the rationale and effectiveness of special tax preferences for small business. Part III examines Canadian experience with the taxation of private companies and their shareholders, illustrating the ways in which Professor Freedman’s concerns about structural tax differentials and tax preferences for small business have played out in the Canadian context. Part IV concludes with a few observations about how best to promote simplicity, neutrality and coherence in the taxation of small business.



To view the content in your browser, please download Adobe Reader or, alternately,
you may Download the file to your hard drive.

NOTE: The latest versions of Adobe Reader do not support viewing PDF files within Firefox on Mac OS and if you are using a modern (Intel) Mac, there is no official plugin for viewing PDF files within the browser window.