Category: Canadian-Controlled Private Corporation

2024 Federal Budget – Major Income Tax Changes Announced

Published by Jonathan Longcroft & Elliott Simpson & Alexander Demner

Yesterday (April 16, 2024), the Department of Finance Canada published its 2024 federal budget (“Budget 2024”). Several major tax proposals were announced. This blog post briefly outlines those relating to income tax.

1. Increased Capital Gains Inclusion Rate 

Quick Update – New EIFEL Regime

Published by Ian Gamble

Context: As part of the avalanche of new draft legislation, the Department of Finance has released revised excessive interest and financing expenses limitation (EIFEL) rules.  The attached Excel is a high-level and technical summary of the new EIFEL regime. …

EU Court of Justice invalidates mandatory reporting obligation imposed on lawyers under DAC6 similar to Canada’s proposed “notifiable transaction” regime

Published by Alexander Demner

The Court of Justice for the European Union (CJEU) recently invalidated a provision derived from the EU Directive informally known as DAC6 which requires lawyers to report their involvement in certain cross-border tax-planning arrangements to third parties. The provisions analyzed…

A Critical Analysis of the Principal Income Tax Measures from Federal Budget 2022 (and Subsequent Legislative Proposals)

Published by Thorsteinssons LLP

Authors: Gloria Wang, Sarah Faber, and Alexander Demner

Budget 2022: A Plan to Grow Our Economy and Make Life More Affordable (“Budget 2022”) was tabled by the Federal Government on April 7, 2022 (“Budget Day”). The government…

Bill C-208 – Department of Finance confirms ITA amendments are in force and modifies its intended approach

Published by Alexander Demner & Alvin Lun

On June 29, 2021, Bill C-208 received Royal Assent. As previously discussed, that Bill amended the federal Income Tax Act (the “Act”) with the intention of facilitating intergenerational business transfers. The amendments sought to accomplish those means by, in…

2021 Federal Budget – A Critical Analysis and Overview of the Principal Proposed Income Tax Measures

Published by Thorsteinssons LLP

Authors: Alexander Demner, Tyler Berg, and Gloria Wang

The federal government released its 2021 budget on April 19, 2021. Coming in as the longest budget in Canadian history, Budget 2021 proposes a myriad of income tax…

Federal Government Tables Budget 2019: Investing in the Middle Class

Published by Tim Barrett

Minister of Finance, Bill Morneau, tabled the 2019 Budget today (“Budget Day”). This Thorsteinssons update summarizes some of the main tax takeaways.

The tax measures introduced in the Budget should not impact the vast majority of businesses. As a pre-election…

Finance Proposes Substantial Changes to Private Corporation Taxation

Published by Thorsteinssons LLP

On July 18, 2017, the Department of Finance released its consultation policy paper on the taxation of private corporations first announced in Budget 2017, along with proposed legislation on some of the topics addressed.

The Minister’s introductory letter acknowledges the…