In 2017, about 60 percent of capital gains taxes were paid by those earning more than $250,000. In this manner, it is normal to expect that a reduction in capital gains taxes – a measure that some policy analysists have advocated for – would disproportionately benefit the top income earners in Canada. However, a recent […]
In CRA interpretation no. 2018-0771851E5, the CRA was asked whether a shareholder who does not actively participate in the business could be exempt from the tax on split income (TOSI) rules on the basis that he or she lent the company money in the past, which has since been repaid by the company several years
Do Repaid Loans Get You Out of the TOSI Rules? CRA Says Maybe Read More »
On October 31, 2018, the Government introduced proposed legislation as part of the Budget Implementation Act, 2018, No. 2 to change the rules for charities so that they have the full ability to pursue their charitable purposes by engaging in non-partisan political activities and the development of public policy. Specifically, the legislation proposes to: Remove
Canadian Government Lifts Restrictions on Political Activities by Registered Charities Read More »
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:
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
Looking Forward to the 2018 Federal Fall Economic Update Read More »
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
Are You A Non-Resident Entity Carrying on Business in Canada? Read More »
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
Part IV Tax – Allocation of Losses ITA 129 New subsections 129(4.1) and (4.2) of the Act are introduced consequential to the introduction of the eligible refundable dividend tax on hand (ERDTOH) and non-eligible refundable dividend tax on hand (NERDTOH) accounts. These new subsections provide an allocation rule for situations in which losses are
Notice of Ways and Means Motion October 2018: Part IV Tax – Allocation of Losses Read More »
Under the current rules, a trust doesn’t have to file a T3 return if it did not earn income or make distributions in the year. Even if a trust is required to file a T3, it doesn’t have to report the identity of all its beneficiaries. In Budget 2018, Finance Canada expressed that there are
If a corporation opts to claim non-capital losses against Part IV tax using paragraphs 186(1)(c) or (d), proposed subsections 129(4.1) and (4.2) prescribe an ordering rule what requires the loss be set off against the Non-Eligible RDTOH account before any of it can be used against the Eligible RDTOH account. Finance Canada provides two simple