Category: Private Company Reorganizations

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. …

SCC confirms application of GAAR to deny tax loss utilization

Published by Joseph Eid

Deans Knight Income Corp. v. Canada, 2023 SCC 16 (“Deans Knight”) involves the application of the general anti-avoidance rule (“GAAR”) to the utilization of non-capital losses and other deductions by a taxpayer, Deans Knight Income Corporation (the “Taxpayer”). Experiencing…

Principal tax measures from Federal Budget 2023 – Part 2: Public company and financial institution measures

Published by Alexei Paish & Gloria Wang & Asif Abdulla

Budget 2023 – A Made-in-Canada Plan: Strong Middle Class, Affordable Economy, Healthy Future (“Budget 2023”) was tabled by the Department of Finance (“Finance”) on March 28, 2023 (“Budget Day”). The stated focus of Budget 2023 includes targeted inflation relief, stronger…

Principal tax measures from Federal Budget 2023 – Part 1: Personal and private company measures

Published by Alexei Paish & Asif Abdulla & Gloria Wang

Budget 2023 – A Made-in-Canada Plan: Strong Middle Class, Affordable Economy, Healthy Future (“Budget 2023”) was tabled by the Department of Finance (“Finance”) on March 28, 2023 (“Budget Day”). The stated focus of Budget 2023 includes targeted inflation relief, stronger…

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…

COVID-19 Tax Update: A Detailed Review of the Recent Changes to the Canada Emergency Wage Subsidy (CEWS)

Published by Ian Humphries & Alexander Demner

Note: To enhance readability, readers may access a PDF COPY OF THIS BLOG POST HERE

I.     OVERVIEW

On July 27, 2020, Parliament enacted Bill C-20 which made sweeping amendments to the Canada Emergency Wage Subsidy (the “CEWS”). The…