Download our PDF version of the comprehensive Tax on Split Income Guide updated for the latest CRA Rulings and examples up to March 2019. This is a great reference tool for tax practitioners.
Section 120.4 – Tax on Split Income (TOSI) – Comprehensive Guide 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:
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
Overview Section 94 deals with the taxation of non-resident trusts (NRTs). In general, if a Canadian resident contributes property to a NRT (other than an “exempt foreign trust”), the NRT is deemed to be resident in Canada for a number of purposes, and the contributor (excepting electing contributors in respect of the NRT), the NRT
Commentary: Section 94 — Non-Resident Trust Rules Read More »
Tax Policy Developments 1977 Budget: The present system of taxation of life insurance companies was introduced in 1969 when, subject to minor exceptions, the industry became liable for a profits tax for the first time. It has taken several years to assess the new tax system for life insurance companies. It is now apparent that major
Commentary: Sections 211-211.1 – Tax on Investment Income of Life Insurers (Part XII.3) Read More »
What is the Tax Policy? Budget 1977 Smaller, and particularly newer companies, very often find it difficult to attract and retain people with the necessary executive skills because they do not have enough financial resources to match the higher salaries offered by larger enterprises. A change in the tax treatment of employee stock options
Commentary: 7(1.1) – Employee Stock Options Issued By CCPCs Read More »
Budget 2015: Expanded the Scope of 55(2) Tax Avoidance of Corporate Capital Gains (Section 55) The Income Tax Act contains an anti-avoidance rule that generally taxes as capital gains certain otherwise tax-deductible inter-corporate dividends. This rule typically applies where a corporation that is about to dispose of shares of another corporation receives from that other corporation tax-deductible