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 …
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. …
The Canada Border Services Agency (“CBSA”) released a consultation paper and proposed regulations amending the Valuation for Duty Regulations on May 27, 2023, with a thirty-day consultation period that ends June 26, 2023. A copy of the proposed regulations…
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…
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…
On December 3, 2021, a unanimous Supreme Court of Canada (“SCC”) dismissed the Crown’s appeal in Canada v. Loblaw Financial Holdings Inc. (2021 SCC 51). In doing so, the Court held that capital contributions and corporate oversight are not relevant…
Last week, the Supreme Court of Canada (“SCC”) dismissed the Crown’s appeal in Canada v. Alta Energy Luxembourg S.A.R.L. (2021 SCC 49). In doing so, the SCC wrestled with important, timely, and politically contentious questions of domestic and international…
Canada taxes its residents on their worldwide income, including income earned and gains realized outside Canada (subject to the potential application of specific rules in tax treaties). The federal Income Tax Act (the “ITA”) also requires that residents disclose specific…
Authored by: Greg DelBigio, Q.C. and Morgan Watchorn
In Budget 2021, the federal government proposes to provide the Canada Revenue Agency (the “CRA”) with $230 million over five years as part of an ongoing focus on enforcing civil liabilities…
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…