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CCPC Passive Investment Income Saga Comes to an End

Joseph Frankovic

BACKGROUND On July 18, 2017, the Department of Finance (“the Department”) released proposals to amend the income tax treatment of certain businesses and in particular Canadian-controlled private corporations (“CCPCs”).[1] The proposals included methods of eliminating the tax deferral advantage that occurs when a CCPC uses its after-tax business income to Read More

Most of Canada’s Tax Treaties Will Get An Instant Rewrite Due To MLI

Michael Atlas

On May 28, 2018, Canada’s Finance Minister tabled a Notice of Ways and Means Motion aimed at introducing legislation to enact the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting. This convention is commonly known as the “Multilateral Instrument”, or “MLI”. The MLI Read More

Legislative Proposals Relating to the Excise Tax Act Released June 27, 2018

Wisam Mshati

The Minister of Finance, Bill Morneau, published new legislative proposals to amend the Excise Tax Act (“ETA”). The amendments introduce new rules regarding the GST/HST treatment of allowances, credit, or similar instruments issued by a government or international organization under a scheme or arrangement implemented to regulate greenhouse gas emissions, Read More

How much tax are Canada’s largest corporations paying?

Cameron Mancell

This week PWC Canada published its annual report on how much tax Canada’s largest corporations pay. PwC Canada surveyed 87 members of the Business Council of Canada. The resulting fifth annual Total Tax Contribution report found that these businesses collectively contributed $68.3 billion to federal, provincial and municipal governments. Together, they make major Read More

Bills Receive Royal Assent and Multilateral Convention Bill Introduced

Cameron Mancell

Today Bill C-45 and Bill C-74 received Royal Assent. Bill C-45, Cannabis Act, legalizes and regulates the sale of cannabis nation-wide. Bill C-74, Budget Implementation Act, 2018, No. 1, implemented several tax measures, including: changes to the tax on split income rules; the passive income changes for private corporations; other income Read More

Nunavut Budget Highlights

Cameron Mancell

Nunavut Finance Minister, David Akeeagok, tabled the 2018-2019 Budget on May 28, 2018. The government projects revenues of $2.177 billion, total expenditures of $1.864 billion, and projects a deficit of $30 million for the fiscal year. Although there were no new taxes or tax breaks announced, here are a few Read More

Minister Tables NWMM to Enact the Multilateral Convention

Cameron Mancell

Minister of Finance, Bill Morneau, has tabled a 59-page Notice of Ways and Means Motion to implement the multilateral instrument (“MLI”). Since Canada signed the MLI last year, it was anticipated that this legislation would be coming eventually. The backgrounder released by the Department of Finance mentions that the legislation Read More

Quebec Favours a Single Personal Tax Return

Cameron Mancell

The Assemblée Nationale (Québec’s parliament) voted unanimously in favor of Québec’s residents being able to file only one (joint federal-Québec) tax return.  This follows a similar suggestion made by Andrew Scheer, leader of the Federal Conservatives. Bill Morneau, federal Finance Minister, seemingly said he was open to Québec making the Read More