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Quebec to Follow Federal Government on Limiting the Small Business Deduction for CCPCs Earning Passive Income

Quebec’s government announced that it will amend its tax legislation to parallel the federal government’s measure – announced as part of the 2018 budget – to grind down the small business deduction limit for CCPCs having between $50,000 and $150,000 in investment income for taxation years that begin after 2018. Quebec’s government announced the following:

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Highlights of Bill Morneau’s 2018 Fiscal Update

Highlights of Bill Morneau’s 2018 fiscal update Overview Responding to U.S. Tax Cuts And Jobs Act of 2017 (TCJA): Enhance capital cost allowance (CCA) in the first year; Immediate expensing for manufacturing and processing and clean energy investments Responding to U.S. Tax Cuts and Jobs Act of 2017 (TCJA) In the U.S., businesses can accelerate

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Looking Forward to the 2018 Federal Fall Economic Update

Looking Forward to the 2018 Federal Fall Economic Update There have been mumblings that Bill Morneau’s 2018 fall economic update will have measures to incentivize capital investments in Canada. One of those measures is allowing businesses to write off their capital assets quicker (even immediately expensing them). Since the motive behind this anticipated change is

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Are You A Non-Resident Entity Carrying on Business in Canada?

Are You A Non-Resident Entity Carrying on Business in Canada? Non-resident Corporations A non-resident corporation is taxable on its income generated from a business carried on in Canada and from the disposition of taxable Canadian property.  This article focuses on business income. Business income Where a non-resident corporation is a resident in a country with

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Summary of Fall Economic Statement – Ontario

Summary of Fall Economic Statement Overview Suggestions to the federal government to address U.S. tax reform Not going along with the federal government’s passive income rules that would limit the small business deduction for CCPCs earning more than $50,000 in passive income A new refundable tax credit: Low-Income Individuals and Families Tax (LIFT) Credit for

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The Federal Court of Appeal Applies GAAR in a Partnership Loss Transfer Strategy: Canada v. 594710 British Columbia Ltd., 2018 FCA 166

Overturning the Tax Court of Canada’s (Tax Court) decision, the Federal Court of Appeal (FCA) ruled in 594710 British Columbia Ltd that GAAR is applicable in a loss utilization strategy where a new partner (Nuinsco) with a significant unused loss balance entered a partnership to facilitate an allocation of virtually all the partnership’s income, availing the former

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