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 […]
T1134 Reporting Requirements Budget 2018 Proposal The Income Tax Act contains specific information reporting requirements in respect of foreign affiliates. In general terms, taxpayers (and certain partnerships) are required to file an information return each year in respect of each of their foreign affiliates in the year T1134). These returns contain, among other things, information about
Budget 2018 At-Risk Rules for Tiered Partnerships The income (or loss) of a partnership for income tax purposes is allocated to its partners, who include (or deduct) the amount in calculating their own income. Limited partners of a partnership may deduct losses of the partnership allocated to them only to the extent of their
Notice of Ways and Means Motion October 2018: At-Risk Rules for Tiered Partnerships Read More »
Passive Investment Income Budget 2018 Active business income earned by private corporations is taxed at corporate income tax rates that are generally lower than personal income tax rates, giving these corporations more money to invest in order to grow their business. In addition, a small Canadian-controlled private corporation (CCPC) can benefit from a corporate
Reassessment Period – Non-Resident Non-Arm’s Length Persons Budget 2018 After a taxpayer files an income tax return for a taxation year, the Canada Revenue Agency (CRA) is required to perform an initial examination of the return and to assess tax payable, if any, with all due dispatch. The CRA then normally has a fixed
Foreign Affiliates Budget 2018 Budget 2018 proposes modifications to the foreign affiliate rules as a result of the Government’s ongoing monitoring of developments in this area. A foreign affiliate of a taxpayer resident in Canada is a non-resident corporation in which the taxpayer has a significant interest. A controlled foreign affiliate of a taxpayer
Notice of Ways and Means Motion October 2018: Foreign Affiliates Read More »
Cross-Border Surplus Stripping Using Partnerships and Trusts Budget 2018 The Income Tax Act contains a rule (section 212.1) that is intended to prevent a non-resident shareholder from entering into transactions to extract free of tax (or “strip”) a Canadian corporation’s surplus in excess of the PUC of its shares, or to artificially increase the