Important Proposed Amendments to the Taxation of Private Corporations
Overview In its 2017 Federal Budget release, the Federal Government noted a continued concern with tax planning strategies involving private corporations. While no new measures or amendments to existing rules were released as part of the 2017 Federal Budget, Canadian...
The Alberta Investor Tax Credit
Introduction On January 1, 2017, the Investing in a Diversified Alberta Economy Act (the “Act”) came into force. The Act is part of the Alberta Jobs Plan, and its objectives are to boost investment in Alberta’s small and medium-sized businesses,...
Introduction
On March 22, 2017, Minister of Finance Bill Morneau tabled the 2017 Federal Budget entitled “Building a Strong Middle Class” (the “Budget”). As is often the case, there was much speculation regarding the Budget, both with respect to how the...
International Tax Measures
International Tax The Budget has only 1 proposed income tax change in the area of international tax. This relates to foreign branches of Canadian resident life insurers. As such, the proposed change is not applicable, and probably not of interest...
Business Income Tax Measures
Investment Fund Mergers The Budget seeks to expand the scope of rules which apply to generally permit the merger of certain investment funds on a tax-deferred basis. As further explained below, these rules will apply to permit the reorganization of...
Personal Income Tax Measures
Disability Tax Credit – Nurse Practitioners The Budget seeks to extend to nurse practitioners the ability to certify that an individual is eligible to receive the disability tax credit available under the Tax Act. The disability tax credit is a...
GST/HST Tax Measures
Taxi and Ride Sharing Services The Budget proposes to extend the application of the GST/HST currently applicable to taxi businesses to ride sharing services. Currently, all operators of a “taxi business” (which is defined in subsection 123(1) of the Excise...
Other Measures
Aboriginal Tax Policy In successive budgets since 1997, the Federal Government has expressed its willingness to put into effect taxation arrangements with interested Aboriginal governments. To date, the Federal Government has entered into more than 50 taxation arrangements in respect...
Previously Announced Measures
The Budget confirms the Federal Government’s intention to proceed with the following previously announced tax and related measures, as modified to take into account consultations and deliberations since their release: Measures announced on October 3, 2016 to improve fairness in...
Rectification is not Equity’s Version of a “Mulligan” – Words to Heed After Fairmont and Coutu
Introduction In Canada’s common law jurisdiction, rectification has historically been a powerful equitable remedy which, if granted, enables applicants to “travel back through time” to correct the documentary basis of transactions that have resulted in unintended detrimental tax or other...
