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Tax facts and figures: Canada 2016

PwC’s 39th edition of Tax facts and figures will help you stay up-to-date on the federal – as well as provincial and territorial – tax changes and determine which apply to you or your company. What’s more – it puts individual and corporate tax rates and tax deadlines at your fingertips.                                                                           Learn more | View now | PDF

Our guides and budgets memos

Tax Insights: 2017 Nova Scotia budget – Tax highlights
On April 27, 2017, Nova Scotia’s Finance and Treasury Board Minister, Hounourable Randy Delorey, delivered the province’s 2017 budget.

Tax Insights: 2017 Ontario budget – Tax highlights
On April 27, 2017, Ontario’s Minister of Finance, Charles Sousa, presented the province’s budget.

Tax Insights: 2017 Manitoba budget – Tax highlights
On April 11, 2017, Manitoba’s Minister of Finance, Cameron Friesen, presented the province’s budget.

Tax Insights: 2017 Quebec budget – Tax highlights
On March 28, 2017, Quebec's Finance Minister, Carlos Leitao, delivered the province's budget.

Tax Insights: Saskatchewan PST alert – Insurance premiums subject to 6% PST on July 1, 2017 
Saskatchewan’s March 22, 2017 budget includes important changes for insurers and brokers, including individual health and life policy providers.

Tax Insights: 2017 Saskatchewan budget – Tax highlights
On March 22, 2017, Saskatchewan’s Minister of Finance, Kevin Doherty, presented the province’s budget.

Tax Insights: 2017 Federal budget: Liberal government – year two
On March 22, 2017, the Federal Minister of Finance, Bill Morneau, presented the Liberal government’s second budget. This Tax Insights discusses the tax initiatives proposed in the budget.

Tax Insights: Quebec provides tax relief in three ways
Quebec Information Bulletin 2017-3, released on February 21, 2017, provides tax relief in three ways. This Tax Insights discusses the details.

Tax Insights: 2017 British Columbia budget – Tax highlights
On February 21, 2017, British Columbia’s Minister of Finance, the Honourable Michael de Jong, presented the province’s budget.

Car expenses and benefits: A tax guide (2017)
Using a vehicle for business means you face an intricate set of tax laws when it comes to claiming your expenses. Find out how you can take advantage of certain tax deductions in this annual guide, summary and employee log.

Tax Insights: 2017 New Brunswick budget – Tax highlights
On February 7, 2017, Finance Minister, Cathy Rogers, delivered New Brunswick's 2017 budget.

Tax Insights: 2017 Federal budget – What could be in it
With Canada’s 2017 federal budget looming, we consider what tax measures our government might have in store for us.

Canadian mining taxation 2016
PwC's Canadian mining taxation 2016 summarizes the Canadian income and mining tax systems and provides guidance from the industry leaders on the complexities of mining taxation in Canada. 

Tax Insights: Ontario changes Land Transfer Tax and Ontario Interactive Digital Media Tax Credit rules
Today, Ontario delivered its 2016 Economic Outlook and Fiscal Review.

Paying Taxes 2017: The Canadian Summary
Paying Taxes 2017, now in its 11th edition, continues to be a unique report from PwC and the World Bank Group. It is the only piece of research which, by using a medium-sized domestic case study company, measures and assesses the ease of paying taxes across 190 economies.

Year-end tax planner – 2016: Helping individuals and owner-managed businesses save tax
The Year-end tax planner is designed primarily for individuals who have accumulated some wealth or own their own businesses (large or small). It includes year-end tax planning checklists.

Oil and gas taxation in Canada
This publication summarizes the way in which Canadian oil and gas operations are taxed by the Canadian federal and western provincial governments.

Insurance industry: Key tax rates and updates – Canada (2016)
Tax changes, rates, deadlines and other useful information for the insurance industry in Canada.

Tax facts and figures: Canada 2016
PwC’s 39th edition of Tax facts and figures will help you stay up-to-date on the federal – as well as provincial and territorial – tax changes and determine which apply to you or your company. What’s more – it puts individual and corporate tax rates and tax deadlines at your fingertips.

Taxation and tax incentives in Ontario 2015
PwC’s second edition of Taxation and tax incentives in Ontario: Your essential guide is an indispensable reference tool for any person or entity that does business in Ontario or is considering doing business in Ontario. It will also help if you live in Ontario or might move here.

Tax Insights: 2016 Manitoba budget – Tax highlights
On May 31, 2016, Manitoba’s Minister of Finance, Cameron Friesen, presented the province’s budget. 

2016 Alberta budget: Tax highlights
On April 14, 2016, Alberta's President of Treasury Board and Minister of Finance, Joe Ceci, presented the province’s 2016 budget.

Tax Insights: Newfoundland and Labrador HST increase – Transitional rules released – Be ready
Newfoundland and Labrador’s April 14, 2016 budget increases the provincial component of Harmonized Sales Tax (HST), on July 1, 2016, from 8% to 10%, resulting in an HST rate of 15%.

Tax Insights: 2016 Newfoundland and Labrador budget – Taxes to increase
On April 14, 2016, the Minister of Finance and President of Treasury Board, Cathy Bennett, delivered Newfoundland and Labrador’s 2016 budget.

Tax Insights: Newfoundland and Labrador increases HST rate to 15% and reintroduces 15% RST on property and casualty insurance premiums
Newfoundland and Labrador’s 2016 budget increases the province’s HST rate to 15% on July 1, 2016, with the provincial portion of the HST increasing from 8% to 10%.

Tax Insights: New Brunswick HST increase – Transitional rules released – Be ready
New Brunswick’s February 2, 2016 budget increases the provincial component of Harmonized Sales Tax (HST), on July 1, 2016, from 8% to 10%, resulting in an HST rate of 15%.

Tax Insights: 2016 Federal budget – Failure to properly report grandparented sales of new housing – act now for relief
The March 22, 2016 federal budget provides relief related to GST/HST reporting of grandparented sales of new housing. This change allows the real estate industry to eliminate exposure to severe penalties for failure to properly report these sales.

Tax Insights: 2016 Federal budget – GST/HST relieving measures for non-arm’s length cross-border reinsurance
The March 22, 2016 federal budget announced measures concerning the application of GST/HST on reinsurance premiums that are paid to non-arm’s length non-resident insurers. These measures will apply to any year ending after November 16, 2005.

2016 Federal budget: A new era with a majority Liberal government 
On March 22, 2016, the Federal Minister of Finance, Bill Morneau, presented the new majority government’s first budget. This Tax Insights discusses the tax initiatives proposed in the budget.

2016 Federal Budget - Instant Reactions
Our reactions and insights to the Federal Budget, are available here.

Tax Insights: 2016-2017 Quebec budget – Tax highlights
The honourable Carlos Leitao, Quebec Minister of Finance, delivered today, March 17, 2016, the 2016-2017 Budget of the Government of Quebec.

Tax Insights: 2016 Ontario budget – Tax highlights
On February 25, 2016, Ontario's Minister of Finance, Charles Sousa, presented the province's budget.

Tax Insights: 2016 British Columbia budget – Tax highlights
On February 16, 2016, British Columbia's Minister of Finance, the Honourable Michael de Jong, presented the province's budget.

Tax Insights: 2016 New Brunswick budget – Tax highlights
On February 2, 2016, Finance Minister, Roger Melanson, delivered New Brunswick's 2016 budget.

Tax Insights: 2016 Federal budget – What could be in it
With Canada's 2016 federal budget looming, we consider what tax measures our new government might have in store for us.

2015 in Review: Canadian Tax and Other Highlights
What were the important changes and tax law updates that occurred in 2015? Our year-in-review timeline provides a detailed overview.

Canadian Insurance Taxation, 4th Edition
This latest edition of Canadian Insurance Taxation represents a comprehensive update written by PwC’s tax partners Jason Swales and Erdem Erinc.

Tax Insights: 2015 Alberta NDP budget – Tax highlights
On October 27, 2015, Alberta's President of Treasury Board and Minister of Finance, Joe Ceci, presented the NDP government's first budget.

The big table: Film and video incentives in Canada 2015
Canada has numerous tax incentives for companies that develop film, video and digital content, including video games. For help understanding these incentives, navigate the interactive maps and read PwC's big table publications.

Tax Insights: Alberta hikes personal and corporate taxes 
As expected, Alberta’s NDP government has not proceeded with the level of personal tax increases, health levy and other tax initiatives proposed by its Conservative predecessors.

Tax Insights: 2015 Manitoba budget – Tax highlights
On April 30, 2015, Manitoba's Finance Minister, Greg Dewar, delivered the province's budget.

Tax Insights: 2015 Newfoundland and Labrador budget – High earners face tax hikes
On April 30, 2015, Nova Scotia's Finance Minister, Ross Wiseman, delivered the province's budget.

2015 Federal Budget - Impact on Immigration
Overall, with respect to immigration law, the Canadian government announced that it remains committed to reforming the Temporary Foreign Worker Program and ensuring that Canadians are first in line for available jobs.

Tax Insights: 2015 Ontario budget – Tax highlights
On April 23, 2015, Ontario's Minister of Finance, Charles Sousa, presented the province's budget.

2015 Federal budget: A pre-election budget
On April 21, 2015, the Federal Minister of Finance, Joe Oliver, presented the majority government's budget. This Tax Insights discusses the tax initiatives proposed in the budget.

Tax Insights: 2015 Federal budget: Good news for foreign employers with frequent business travellers to Canada
Foreign employers with non-resident employees temporarily working in Canada will welcome a 2015 federal budget proposal that provides relief from payroll withholding requirements.

2015 Federal Budget - Instant Reactions
Our reactions and insights to the Federal Budget, tabled on April 21, 2015 by Federal Minister of Finance, Joe Oliver, are available here.

Tax Insights: 2015 Nova Scotia budget – Tax highlights
On April 9, 2015, Nova Scotia's Finance and Treasury Board Minister, Diana Whalen, delivered the province's budget.

Tax Insights: 2015 New Brunswick budget – High earners face big tax hikes
On March 31, 2015, Finance Minister, Roger Melanson, delivered New Brunswick's 2015 budget.

Tax Insights: 2015 Alberta Budget – Many Albertans to pay more
On March 26, 2015, Alberta's President of Treasury Board and Minister of Finance, Robin Campbell, presented the province's budget.

Tax Insights: 2015 Quebec budget
The Minister of Finance, Carlos Leitao, confirmed in his Budget Speech today that fiscal balance will be restored in 2015-2016. Here are the highlights of the 2014-2015 budget.

Tax Insights: 2015 Quebec budget – Tax highlights
The honourable Carlos Leitao, Quebec Minister of Finance, delivered today, March 26, 2015, the 2015 2016 Budget of the Government of Quebec. Below are the highlights of the most important tax measures included in the budget.

Tax Insights: 2015 Saskatchewan budget – Tax highlights
On March 18, 2015, Saskatchewan’s Minister of Finance, the Honourable Ken Krawetz, presented the province’s budget. The budget does not increase corporate or personal income tax rates, but does curtail certain tax incentives.

Tax Insights: 2015 British Columbia budget – Tax highlights
On February 17, 2015, British Columbia’s Minister of Finance, the Honourable Michael de Jong, presented the province’s budget.

Corporate tax

Tax Insights: Deductibility of employee share plan costs: CRA’s new guidance – what it means for you 
The Canada Revenue Agency has updated its position on employer deductions for share plans that settle in newly issued stock.

Tax Insights: Common Reporting Standard becomes effective July 1, 2017 – Be ready
The Common Reporting Standard for automatic information exchange becomes effective July 1, 2017, in Canada.

Corporate tax rates and legislation: Q1 2017 Accounting status
This quarterly update discusses developments related to the accounting for income taxes in Canada.

Tax Insights: Federal Court of Appeal limits CRA access to tax accrual working papers
On March 30, 2017, the Federal Court of Appeal ruled that the Minister of National Revenue does not have “general and unrestricted access” to taxpayers’ identification of their uncertain tax positions.

Tax Insights: Quebec – Disclosure of conditional remuneration agreements required by April 8, 2017
If your company concluded a conditional remuneration service agreement with a service provider for preparing a Quebec tax credit claim of $25,000 or more, ensure Form TP-1079.DI-V “Mandatory or Preventative Disclosure of Tax Planning” has been filed for tax operations that were completed after March 25, 2015. If this was not done, you have until April 8, 2017, to file the form and avoid penalties.

Tax Insights: Quebec provides tax relief in three ways
Quebec Information Bulletin 2017-3, released on February 21, 2017, provides tax relief in three ways. This Tax Insights discusses the details.

Tax Insights: Government commits to aggressive timelines for recommendations on tax avoidance and tax evasion
On February 22, 2017, the Minister of National Revenue responded to the 14 recommendations in the House of Commons Standing Committee on Finance report “The Canada Revenue Agency, Tax Avoidance and Tax Evasion: Recommended Actions,” dated October 26, 2016.

Tax Insights: 2017 Annual tax filing and remittance deadlines for corporations
This Tax Insights outlines some of the more common corporate compliance requirements to be considered at this time of year.

Corporate tax rates and legislation: Q4 2016 Accounting status
This quarterly update discusses developments related to the accounting for income taxes in Canada.

Tax Insights: CRA’s new policy – Effect on planholders and financial institutions
During the 2016 Canadian Tax Foundation Conference, the CRA stated that the payment of investment management fees in respect of registered plans, such as RRSPs, RRIFs or TFSAs, by a plan annuitant or holder will, in most cases, create an “advantage.”

Tax Insights: Voluntary Disclosures Program in jeopardy
On December 8, 2016, the Canada Revenue Agency released “Report on the Voluntary Disclosures Program,” which sets out recommendations of the Offshore Compliance Advisory Committee.

Tax Insights: Improvements coming to income tax objection process – What they are
The 2016 Fall Reports of the Auditor General of Canada examines whether the Canada Revenue Agency has efficiently managed income tax objections. 

Tax Insights: CRA fishing net expands
The Canada Revenue Agency (CRA) intends to expand its review of international electronic funds transfers (EFTs); in 2017-18 it will review 100,000 EFTs involving targeted jurisdictions. As a result of this strategic audit initiative, many taxpayers can expect an “EFT letter” next year as part of their increasing compliance burden.

Paying Taxes 2017: The Canadian Summary
Paying Taxes 2017, now in its 11th edition, continues to be a unique report from PwC and the World Bank Group. It is the only piece of research which, by using a medium-sized domestic case study company, measures and assesses the ease of paying taxes across 190 economies.

Tax Insights: Ontario changes Land Transfer Tax and Ontario Interactive Digital Media Tax Credit rules
Today, Ontario delivered its 2016 Economic Outlook and Fiscal Review.

Tax Insights: House of Commons Standing Committee on Finance targets tax avoidance and evasion
On October 27, 2016, the House of Commons Standing Committee on Finance released its report “The Canada Revenue Agency, Tax Avoidance and Tax Evasion: Recommended Actions.” The report summarizes the testimony received by the Committee during three hearings and includes 14 recommendations. 

Tax Insights: Bill C-29 – Effect on asset management industry
Bill C-29, Budget Implementation Act, 2016, No. 2, which received first reading on October 25, 2016, includes measures that affect the asset management industry.

SR&ED Tax clip: Federal investment tax credits for R&D and property – 2016 (July 27, 2016) 
Canada offers one of the most favourable packages of R&D tax incentives among the major industrialized countries. Federal, provincial and territorial R&D tax incentives are available.

SR&ED Tax clip: Provincial and territorial R&D tax credits - 2016 (July 27, 2016)
Canada offers one of the most favourable packages of R&D tax incentives among the major industrialized countries. In addition to the federal incentives, taxpayers carrying on R&D can also benefit from provincial or territorial tax credits.

Corporate tax rates and legislation: Q3 2016 Accounting status
This quarterly update discusses developments related to the accounting for income taxes in Canada.

Tax Insights: FCA’s decision in Kruger – Accounting provides an accurate picture of income for derivatives

On June 22, 2016, the Federal Court of Appeal (FCA) released its decision in Kruger Incorporated v. Her Majesty the Queen. The FCA reversed the Tax Court of Canada’s decision on two significant issues

Corporate tax rates and legislation: Q2 2016 Accounting status
This quarterly update discusses developments related to the accounting for income taxes in Canada.

Tax Insights: SCC strikes down Minister’s authority to demand records subject to privilege
Two recent Supreme Court of Canada (SCC) cases are the latest of recent developments reminding taxpayers that communications involving tax risks and strategy can be subject to privilege, and therefore do not have to be disclosed to the Canada Revenue Agency.

In Print: The "Purpose" of Subsection 55(2)
Subsection 55(2) of the Income Tax Act (Canada) is a specific anti-avoidance rule aimed at "capital gain strips" and has been in the Act for over 30 years.

Tax Insights: Alert for asset managers – New final section 871(m) regulations on dividend equivalent payments may apply to you
On September 17, 2015, the IRS released final and temporary regulations under Section 871(m) of the Internal Revenue Code that prescribe rules for treating “dividend equivalent payments” with respect to US equities as US-source dividend income.

Tax Insights: Legislative proposals implement the Common Reporting Standard – Are you ready?
On April 15, 2016, the Department of Finance released draft legislative proposals to implement the Common Reporting Standard.

Tax Insights: New initiatives target tax evasion and tax avoidance
On April 11, 2016, the Honourable Diane Lebouthillier, Minister of National Revenue, outlined measures that the government will implement to combat what it perceives as “aggressive” tax avoidance – strategies that adhere to Canada’s tax laws but may contravene its intention – and tax evasion.

Corporate tax rates and legislation: Q1 2016 Accounting status
This quarterly update discusses developments related to the accounting for income taxes in Canada.

Tax Insights: Draft Form W-8BEN-E – How it affects Canadian financial institutions and other entities
On January 15, 2016, the IRS released a draft of Form W-8BEN-E, Certificate of Status of Beneficial Owner for United States Tax Withholding and Reporting, and draft Instructions for Form W-8BEN-E.

Tax Insights: Partnership exemption for Ontario land transfer tax retroactively eliminated for trusts and partnerships
On February 18, 2016, the Ontario Ministry of Finance introduced certain retroactive amendments to Regulation 70/91 under the Land Transfer Tax Act.

Tax Insights: Ontario Retirement Pension Plan – Delayed until 2018
Large corporations will not be required to remit Ontario retirement pension plan (ORPP) premiums until January 2018 – one year later than originally announced. The federal government will work with Ontario to facilitate ORPP administration.

Tax Insights: 2016 Annual tax filing and remittance deadlines for corporations
This Tax Insights outlines some of the more common corporate compliance requirements to be considered at this time of year.

Corporate tax rates and legislation: Q4 2015 Accounting status
This quarterly update discusses developments related to the accounting for income taxes in Canada.

The Top 10 considerations if you're being audited by the CRA
Are you are being audited by the Canada Revenue Agency? There are a number of key actions you can take to minimize the effort and time invested.

Tax Insights: Alert for private corporations – Some tax rates to increase
A Notice of Ways and Means Motion released by the Department of Finance on December 7, 2015, includes several tax changes that were not previously mentioned.

In Print: George Weston and the Characterization of Gains on Derivatives
The authors of this article argue that the Tax Court of Canada’s decision in George Weston Limited v. The Queen is a natural and expected result of 75 years of UK and Canadian jurisprudence on the treatment of foreign exchange gains and losses and gains and losses arising from hedging activity such as currency swaps and commodity futures trading.

Tax Insights: Expected changes for taxing stock options – Be prepared
The federal Liberal party has pledged to cap the amount that employees can claim through stock option deductions, although “employees with up to $100,000 in annual stock option gains will be unaffected.” Details on how and when this change will be made are not yet known.

Tax Insights: Ontario’s Interactive Digital Media Tax Credit – What has changed
On November 2, 2015, Ontario released draft regulations that limit eligibility for the Ontario Interactive Digital Media Tax Credit (OIDMTC).

Tax Insights: Liberal party tax platform – What it could mean for you
Now that the results of Canada’s federal election are in, let’s look at Liberal party promises that can affect taxpayers and steps you can take to save tax.

Tax Insights: July 31, 2015 draft proposals – Alert for the mining industry
The Canadian mining industry will be affected by draft legislative proposals released by the Department of Finance on July 31, 2015.

Corporate tax rates and legislation: Q2 2015 Accounting status 
This quarterly update discusses developments related to the accounting for income taxes in Canada.

Tax Insights: Alberta hikes personal and corporate taxes 
As expected, Alberta’s NDP government has not proceeded with the level of personal tax increases, health levy and other tax initiatives proposed by its Conservative predecessors.

Tax Insights: TCC’s decision in Kruger – Valuation of option contracts 
On May 26, 2015, the Tax Court of Canada (TCC) released its decision in Kruger Incorporated v. Her Majesty the Queen. The TCC considered whether Kruger was entitled, in computing its income for the 1998 taxation year, to deduct $91 million relating to a “mark-to-market” adjustment on unrealized foreign exchange option contracts.

Corporate Tax Rates and Legislation: Q1 2015 Accounting Status 
This quarterly update discusses developments related to the accounting for income taxes in Canada.

Operationalize your tax strategy: Tax Operations Manager 
The tax function is often overlooked as an area for improvement. Shining a light on this area can reveal untapped opportunities where updates in technology, process, people, and/or data can lead to benefits for the broader business.

Personal tax

Tax Insights: Ontario imposes new 15% tax on foreign buyers of residential property
Foreign purchasers of residential property in the Greater Golden Horseshoe will be liable for a new 15% non-resident speculation tax. The new tax will apply to agreements of purchase and sale signed after April 20, 2017.

Tax Insights: The snowbirds sing… and the IRS listens (2017 update)
This Tax Insights outlines the current US income tax rules. These rules apply to all Canadians. The immigration proposal contemplates changes to the Internal Revenue Code to accommodate the extended stay.

Tax Insights: Quebec provides tax relief in three ways
Quebec Information Bulletin 2017-3, released on February 21, 2017, provides tax relief in three ways. This Tax Insights discusses the details.

Tax Insights: Government commits to aggressive timelines for recommendations on tax avoidance and tax evasion
On February 22, 2017, the Minister of National Revenue responded to the 14 recommendations in the House of Commons Standing Committee on Finance report “The Canada Revenue Agency, Tax Avoidance and Tax Evasion: Recommended Actions,” dated October 26, 2016.

Tax Insights: Estate tax update – US estate tax exposure for Canadians (2017 edition) 
This Tax Insights considers the exposure of Canadian residents to US estate tax.

Tax Insights: Moving to Canada – What you need to know about Canadian income tax
Canada’s reputation as a great place to live and do business attracts immigrants from around the world. If you’re thinking of moving to Canada, this Tax Insights will tell you what you need to know about Canadian income tax. 

Tax Insights: CRA’s new policy – Effect on planholders and financial institutions
During the 2016 Canadian Tax Foundation Conference, the CRA stated that the payment of investment management fees in respect of registered plans, such as RRSPs, RRIFs or TFSAs, by a plan annuitant or holder will, in most cases, create an “advantage.”

Tax Insights: Voluntary Disclosures Program in jeopardy
On December 8, 2016, the Canada Revenue Agency released “Report on the Voluntary Disclosures Program,” which sets out recommendations of the Offshore Compliance Advisory Committee.

Tax Insights: Improvements coming to income tax objection process – What they are
The 2016 Fall Reports of the Auditor General of Canada examines whether the Canada Revenue Agency has efficiently managed income tax objections. 

Tax Insights: CRA fishing net expands
The Canada Revenue Agency (CRA) intends to expand its review of international electronic funds transfers (EFTs); in 2017-18 it will review 100,000 EFTs involving targeted jurisdictions. As a result of this strategic audit initiative, many taxpayers can expect an “EFT letter” next year as part of their increasing compliance burden.

Tax Insights: Ontario changes Land Transfer Tax and Ontario Interactive Digital Media Tax Credit rules
Today, Ontario delivered its 2016 Economic Outlook and Fiscal Review.

Tax Insights: House of Commons Standing Committee on Finance targets tax avoidance and evasion
On October 27, 2016, the House of Commons Standing Committee on Finance released its report “The Canada Revenue Agency, Tax Avoidance and Tax Evasion: Recommended Actions.” The report summarizes the testimony received by the Committee during three hearings and includes 14 recommendations. 

Tax Insights: Bill C-29 – Effect on asset management industry
Bill C-29, Budget Implementation Act, 2016, No. 2, which received first reading on October 25, 2016, includes measures that affect the asset management industry.

Tax Insights: Selling your home? Reporting is now required
Starting with the 2016 taxation year, if you sell your principal residence, you will be required to report certain information on your income tax return for the sale to be tax-free.

Tax Insights: Canada targets trusts and non-residents holding residential property 
“To improve tax fairness for Canadian homeowners,” the Department of Finance released a Notice of Ways and Motion today that targets trusts and non-residents owning residential property.

Tax Insights: Gerbro Holdings – TCC did not apply offshore investment fund rules to investment in tax haven
In its recent decision in Gerbro Holdings Company v. The Queen, the Tax Court of Canada refused to apply the offshore investment fund tax rules (in section 94.1 of the Income Tax Act (Canada)) to interests held by a Canadian investor in funds based in low- or no-tax jurisdictions—in this case five funds based in the Cayman Islands, the Netherlands Antilles and the British Virgin Islands. 

Tax Insights: Mutual fund switch corporations – Draft legislative proposals implement 2016 federal budget measures
On July 29, 2016, the Department of Finance released for consultation draft legislative proposals implementing the 2016 federal budget measure that is intended to eliminate the tax-deferred switching of different classes of shares issued by a mutual fund corporation – commonly referred to as “switch funds.”

The Top 10 considerations if you're being audited by the CRA
Are you are being audited by the Canada Revenue Agency? There are a number of key actions you can take to minimize the effort and time invested.

Tax Insights: SCC strikes down Minister’s authority to demand records subject to privilege
Two recent Supreme Court of Canada (SCC) cases are the latest of recent developments reminding taxpayers that communications involving tax risks and strategy can be subject to privilege, and therefore do not have to be disclosed to the Canada Revenue Agency.

Tax Insights: New initiatives target tax evasion and tax avoidance
On April 11, 2016, the Honourable Diane Lebouthillier, Minister of National Revenue, outlined measures that the government will implement to combat what it perceives as “aggressive” tax avoidance – strategies that adhere to Canada’s tax laws but may contravene its intention – and tax evasion.

Tax Insights: Charitable donations – How much tax can you save? It may be less than you think
Canada’s income tax system encourages gifts by individuals to Canadian charities (and other qualified donees).

Tax Insights: Partnership exemption for Ontario land transfer tax retroactively eliminated for trusts and partnerships
On February 18, 2016, the Ontario Ministry of Finance introduced certain retroactive amendments to Regulation 70/91 under the Land Transfer Tax Act.

Tax Insights: Ontario Retirement Pension Plan – Delayed until 2018
Large corporations will not be required to remit Ontario retirement pension plan (ORPP) premiums until January 2018 – one year later than originally announced. The federal government will work with Ontario to facilitate ORPP administration.

Tax Insights: Trust loss restriction rules – Draft legislative proposals modify tax rules affecting funds and asset managers
On January 15, 2016, the Department of Finance released for consultation draft legislative proposals that would amend the “trust loss restriction rules.” The proposals address certain concerns raised by the asset management industry with the currently enacted rules.

Tax Insights: Draft legislative proposals modify tax rules for certain trusts and their beneficiaries
Draft legislative tax proposals released for consultation by the Department of Finance on January 15, 2016, modify the rules for estate donations and spousal and common-law partner (and similar) trusts.

Tax Insights: Estate tax update – Owning a US vacation home (2016 edition) 
If you are a Canadian resident who owns US real estate, learn about your potential estate tax liability and how to reduce it.

Tax Insights: Estate tax update – Canadians living in the United States (2016 edition) 
This Tax Insights explains how the United States determines US residency for estate and gift tax purposes.

Tax Insights: Estate tax update – Canadians transferred to the US (2016 edition) 
US estate, gift and generation-skipping transfer tax exposure for Canadians transferred to the United States.

Tax Insights: Estate tax update – Owning US securities (2016 edition) 
This Tax Insights discusses the application of estate tax to US securities and helps you to hold US securities in a tax-effective way, for example, by using a Canadian holding company.

Tax Insights: Estate tax update – US estate tax exposure for US citizens living in Canada (2016 edition) 
The interaction of US and Canadian tax rules can have important implications for US citizens living in Canada.

Tax Insights: Estate tax update – US family members in the Canadian family-owned business (2016 edition) 
Estate and will planning implications for US family members of Canadian family-owned businesses.

Tax Insights: Taxes for high earners to increase January 1, 2016 – Act now to save!
The Finance Minister confirmed that the top personal tax rate will increase on January 1, 2016. Find out what you might do to reduce the bite.

Tax Insights: New tax rules for spousal, common-law, alter ego and joint partner trusts – Finance has heard our concerns
We are pleased to share with you a letter from the Department of Finance that comments on concerns relating to new tax rules for spousal, common-law, alter ego and joint partner trusts that apply starting January 1, 2016.

Tax Insights: Expected changes for taxing stock options – Be prepared
The federal Liberal party has pledged to cap the amount that employees can claim through stock option deductions, although “employees with up to $100,000 in annual stock option gains will be unaffected.” Details on how and when this change will be made are not yet known.

Tax Insights: Liberal party tax platform – What it could mean for you
Now that the results of Canada’s federal election are in, let’s look at Liberal party promises that can affect taxpayers and steps you can take to save tax.

Tax Insights: New tax rules for trusts apply January 1, 2016 – It’s time to start planning
Changes to the tax treatment of trusts that apply starting January 1, 2016, have stimulated a lot of interest. A key change eliminates graduated tax rates for testamentary trusts and estates unless certain conditions are met.

Tax Insights: Travelling to the United States? Time to start counting your days
Every time you cross the border into the United States you could be getting closer to a US filing requirement.

Tax Insights: Alberta hikes personal and corporate taxes 
As expected, Alberta’s NDP government has not proceeded with the level of personal tax increases, health levy and other tax initiatives proposed by its Conservative predecessors.

US Offshore Voluntary Disclosure podcast series - A five-part Tax Tracks podcast series 
This podcast series sheds light on the question of whether an individual falls under the category of ‘US citizen’ and how to become compliant with the requisite US filings.

Sales tax, VAT and trade

Tax Insights: Saskatchewan PST changes – What they mean for your business
Saskatchewan Bill 70, The Provincial Sales Tax Amendment Act, 2017 (royal assent May 17, 2017), implements most of the PST changes introduced in the province’s March 22, 2017 budget, as well as other PST measures that have important implications for the natural resource extractive and construction industries.

Tax Insights: GST/HST alert – Recover GST/HST self-assessed for non-arm’s length cross-border reinsurance – Act by June 22, 2017
As a result of legislative amendments, Canadian-resident insurers may be able to recover the GST/HST self-assessed on  the “loading” portion of non-arm’s length cross-border reinsurance premiums paid for the 2005 to 2016 fiscal years.

Tax Insights: Saskatchewan PST alert – Insurance premiums subject to 6% PST on July 1, 2017 
Saskatchewan’s March 22, 2017 budget includes important changes for insurers and brokers, including individual health and life policy providers.

Tax Insights: BC provides some foreign buyers relief from 15% property transfer tax
On March 17, 2017, BC announced relief from its 15% foreign buyers’ property transfer tax

Tax insights: CBSA announces Phase 1 2017 verification priorities – What they mean for importers
The Canada Border Services Agency (CBSA) has released its 2017 Phase 1 (January) national trade verification (Audit) priorities.

Tax Insights: The Potential Impact of the U.S. Election on Mexico, Canada, and U.S. Trade Relations
The election of Donald Trump as 45th President of the United States could result in significant changes to U.S. trade policy that may ultimately impact Mexican, Canadian, and U.S. businesses trading with each other.

Tax Insights: GST/HST alert – Participating employers must remit GST/HST collected on deemed supplies to pension entities – act by December 31, 2016
Proposed GST/HST legislation released by the Department of Finance on July 22, 2016, has important implications for pension entities including those that use a master pension entity (i.e. master trust).

Tax Insights: Alberta carbon levy – Regulations fill in the details
Alberta’s carbon levy will be imposed starting January 1, 2017. On November 3, 2016, Alberta released regulations that fill in the details on the levy’s administrative regime, including the collection and remittance process and how the levy will apply to various sectors. 

Tax Insights: CETA (finally) on track for implementation
The Canada-European Union (EU) Comprehensive Economic and Trade Agreement (CETA) was signed on October 30, 2016, in Brussels. The CETA covers a broad ranges of trade issues and has important implications for both EU and Canadian importers, exporters and investors.

Tax Insights: GST/HST and QST alert – Investment plans are required to obtain investor percentages – actions required by September 30, 2016
Distributed investment plans that are a selected listed financial institution are required to obtain information from investors to determine the plan’s provincial attribution percentage, so that the plan's GST/HST and QST liabilities can be calculated. Exchange-traded funds and exchange-traded series are excluded from this requirement.

Tax Insights: GST/HST alert for investment plans
On July 22, 2016, the Department of Finance released “Consultation paper: Proposals for Consultation concerning the GST/HST treatment of Certain Limited Partnerships and Investment Plans,” which will be of interest to Canada’s asset management industry.

Tax Insights: GST/HST alert – Changes to drop shipment rules 
On July 22, 2016, the Department of Finance released draft GST/HST legislative proposals that affect the “drop shipment” provisions in the Excise Tax Act. Most of the changes will apply to transactions occurring after July 22, 2016.

Tax Insights: GST/HST alert for pension plans and master trusts
On July 22, 2016, the Department of Finance released draft GST/HST legislative amendments that affect pension plans, including those that use master trusts or master corporations. 

Tax Insights: BC imposes new 15% tax on foreign buyers of residential property
Foreign purchasers of residential property in the Greater Vancouver Regional District will be liable for a new 15% property transfer tax. The new tax will apply on transfers registered after August 1, 2016, regardless of when the contract of purchase and sale was entered into. It will apply in addition to British Columbia’s general property transfer tax.

Tax Insights: CBSA announces Phase 2 2016 audit priorities – What they mean for importers
The Canada Border Services Agency has released its Phase 2 (July), 2016 national trade verification (Audit) priorities.

Tax Insights: Do you export from Canada? Prepare for heightened enforcement of Canada’s export laws
The Canada Border Services Agency recently announced that many goods exported from Canada have not been reported in accordance with the Customs Act.

Tax Insights: Newfoundland and Labrador HST increase – Transitional rules released – Be ready
Newfoundland and Labrador’s April 14, 2016 budget increases the provincial component of Harmonized Sales Tax (HST), on July 1, 2016, from 8% to 10%, resulting in an HST rate of 15%.

Tax Insights: Sales tax changes coming soon – Are you ready?
Harmonized Sales Tax (HST) rates will increase in three provinces – New Brunswick, Newfoundland and Labrador, and Prince Edward Island – in 2016.

Tax Insights: July 1, 2016 – Ontario recapture rate for recaptured input tax credits declines
On July 1, 2016, Ontario’s rate for certain businesses to recapture the provincial portion of Ontario HST claimed as ITCs in respect of specified property and services will decline from 75% to 50%. The rate is being phased out over four years.

Tax Insights: Newfoundland and Labrador increases HST rate to 15% and reintroduces 15% RST on property and casualty insurance premiums
Newfoundland and Labrador’s 2016 budget increases the province’s HST rate to 15% on July 1, 2016, with the provincial portion of the HST increasing from 8% to 10%.

Tax Insights: New Brunswick HST increase – Transitional rules released – Be ready
New Brunswick’s February 2, 2016 budget increases the provincial component of Harmonized Sales Tax (HST), on July 1, 2016, from 8% to 10%, resulting in an HST rate of 15%.

Tax Insights: 2016 Federal budget – Failure to properly report grandparented sales of new housing – act now for relief
The March 22, 2016 federal budget provides relief related to GST/HST reporting of grandparented sales of new housing. This change allows the real estate industry to eliminate exposure to severe penalties for failure to properly report these sales.

Tax Insights: 2016 Federal budget – GST/HST relieving measures for non-arm’s length cross-border reinsurance
The March 22, 2016 federal budget announced measures concerning the application of GST/HST on reinsurance premiums that are paid to non-arm’s length non-resident insurers. These measures will apply to any year ending after November 16, 2005.

Tax Insights: CBSA announces Phase 1 2016 audit priorities – What they mean for importers
The Canada Border Services Agency (CBSA) recently released its Phase 1, 2016 national trade verification (Audit) priorities.

Commodity Clips, 2015 Issue 4 
This edition of Commodity Clips describes recent commodity tax developments.

Tax Insights: Newfoundland and Labrador’s HST rate to remain 13%
Newfoundland and Labrador’s Premier-designate, Dwight Ball, has confirmed that the province’s HST rate will remain 13%. The former government had planned to increase the rate to 15% on January 1, 2016 (i.e. the provincial portion of the rate was to increase from 8% to 10%).

Tax Insights: GST/HST and QST alert – 10 tax tips to consider at year end
With December 31, 2015 just around the corner, we share 10 GST/HST and QST tips that you should consider now.

Tax Insights: New QST filing and reporting requirement for investment plan managers – Action required by November 20, 2015
Significant QST legislative amendments concerning investment plan managers received royal assent on October 21, 2015

Tax Insights: GST/HST and QST alert – Investment plans are required to obtain investor percentages – actions required by September 30, 2015 
Distributed investment plans that are a selected listed financial institution are required to obtain information from investors to determine the plan’s provincial attribution percentage, so that the plan's GST/HST and QST liabilities can be calculated. Exchange-traded funds and exchange-traded series are excluded from this requirement.

Tax Insights: CBSA announces Phase 2 2015 audit priorities – What they mean for importers
The Canada Border Services Agency recently released its Phase 2 (July) 2015 national trade verification (Audit) priorities. Phase 1 2015 audit priorities were released January 2015.

Tax Insights: July 1, 2015 – Ontario phases out recapture rate for recaptured input tax credits 
This Tax Insights summarizes the changes to the recaptured input tax credit (RITC) reporting requirements.

Tax Insights: US COOL – Hot topic for Canadian traders 
The World Trade Organization’s (WTO) Appellate Body recently released its final report, upholding previous findings that the US Country of Origin Labelling (COOL) measures violate WTO trade rules and unfairly discriminate against beef and hog products imported into the United States.

Tax Insights: Indirect tax deadlines – Ensure you comply 
If you are responsible for your company’s indirect tax obligations, ensure you meet the deadlines discussed in this Tax Insights.

Commodity Clips, 2015 Issue 3
This edition of Commodity Clips describes recent commodity tax developments.

Commodity Clips, 2015 Issue 2
This edition of Commodity Clips describes recent commodity tax developments.

International tax

Tax Insights: Government commits to aggressive timelines for recommendations on tax avoidance and tax evasion
On February 22, 2017, the Minister of National Revenue responded to the 14 recommendations in the House of Commons Standing Committee on Finance report “The Canada Revenue Agency, Tax Avoidance and Tax Evasion: Recommended Actions,” dated October 26, 2016.

In Print: Is the back-to-back withholding tax regime an effective anti-treaty-shopping measure?
This article reviews the operation of the new back-to-back regime as an anti-treatyshopping measure and suggests limited modifications that should be considered to increase the effectiveness of the rules and prevent the denial of treaty benefits in inappropriate circumstances.

Tax Insights: OECD releases long-awaited multilateral instrument – What it means for BEPS
On November 24, 2016, the OECD released the long-awaited Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting, also described as the “multilateral instrument.”

Tax Insights: Bill C-29 significantly expands back-to-back rules
Bill C-29, Budget Implementation Act, 2016, No. 2, which received first reading on October 25, 2016, significantly expands the back-to-back rules for non-resident withholding tax.

Tax Insights: House of Commons Standing Committee on Finance targets tax avoidance and evasion
On October 27, 2016, the House of Commons Standing Committee on Finance released its report “The Canada Revenue Agency, Tax Avoidance and Tax Evasion: Recommended Actions.” The report summarizes the testimony received by the Committee during three hearings and includes 14 recommendations. 

September 16, 2016 Draft proposals: What they mean for international transactions
On September 16, 2016, the Department of Finance released draft legislative proposals relating to technical amendments to the Income Tax Act and Income Tax Regulations that could have important tax implications for international transactions. 

The impact of BEPS on Global Mobility
A number of the BEPS actions will impact on how organizations manage and report on their globally mobile workforce.

Tax Insights: Canada proposes country-by-country reporting in its 2016 federal budget
On March 22, 2016, the federal government tabled its annual budget, which proposes implementing annual country-by-country reporting for Canadian-parented multinationals.

In Print: 2014 saw significant work on BEPS, as well as some notable decisions
The 2014 year continued to bring significant changes to the global transfer pricing landscape, which in turn influenced the Canadian transfer pricing environment.

In Print: Recommended Amendments to the Upstream Loan Rules 
The upstream loan rules announced on August 19, 2011 and enacted on June 26, 2013 require an analysis of all loans or indebtedness owing to foreign affiliates of a Canadian taxpayer.

10 Minutes on the OECD’s BEPS project 
The OECD’s1 base erosion and profit shifting (BEPS) project will likely to spur the most significant changes to the taxation of international business since 1986.

Global mobility services

Tax Insights: Deductibility of employee share plan costs: CRA’s new guidance – what it means for you 
The Canada Revenue Agency has updated its position on employer deductions for share plans that settle in newly issued stock.

Tax Insights: BC provides some foreign buyers relief from 15% property transfer tax
On March 17, 2017, BC announced relief from its 15% foreign buyers’ property transfer tax

Immigration Insights: Want to attract global talent to Canada? Government initiatives can help
Is your company a Canadian company that wants to attract and retain global talent or a foreign company that wants to attract and retain global talent for new or expanded operations in Canada? If so, several recently announced Canadian-government initiatives and Canadian immigration developments can help.

Immigration Insights: Applying for a US EB-5 green card? Act now
The US Congress has extended the EB-5 visa program until April 28, 2017, when significant program changes will likely come into effect. 

Tax Insights: Moving to Canada – What you need to know about Canadian income tax
Canada’s reputation as a great place to live and do business attracts immigrants from around the world. If you’re thinking of moving to Canada, this Tax Insights will tell you what you need to know about Canadian income tax. 

Immigration Insights: 2016 US presidential election – Where the candidates stand on immigration
The issue of immigration has been at the forefront of the US presidential election. This Insights outlines Hillary Clinton’s and Donald Trump’s immigration proposals and observes what these proposals could mean for corporate immigration. 

Tax Insights: Non-Resident Employer Certification program – Compliance reviews and other updates
Earlier this year, the CRA introduced its Non-Resident Employer Certification program, which exempts from Canadian payroll withholding requirements certain foreign employers with certain non-resident employees working temporarily in Canada. 

Tax Insights: Budget 2016 – Canada confirms intention to reintroduce legislative changes to payroll withholding compliance for non-resident employers
Canada’s March 22, 2016 federal budget has confirmed the intention to proceed with proposed legislative changes to Canadian payroll withholding compliance requirements for non-resident employers with non resident employees working temporarily in Canada.

Top 10 global mobility issues for corporate Tax Directors: a Canadian perspective 
Companies today are implementing global mobility programs that often involve complex international relocations. The activities of individuals in foreign locations can create a variety of both individual and corporate level tax compliance issues for the enterprise that can become unexpectedly complex to address.

Tax Insights: New Non-Resident Employer Certification program – Payroll withholding relief for foreign employers with frequent business travellers to Canada
On January 12, 2016, the Canada Revenue Agency released its Non-Resident Employer Certification program for foreign employers with non-resident employees temporarily working in Canada.

Immigration Insights: Election 2015 – Federal parties’ immigration commitments
With the federal election on the horizon, we expect that each of the federal parties will be releasing additional details regarding their immigration platforms in the coming weeks.

The impact of BEPS on Global Mobility
A number of the BEPS actions will impact on how organizations manage and report on their globally mobile workforce.

Tax Insights: Canadian payroll relief clarified for foreign employers with frequent business travellers to Canada 
On July 31, 2015, the Department of Finance released draft legislative proposals (July 31 proposals), which modify 2015 federal budget measures that provide foreign employers with non-resident employees temporarily working in Canada relief from payroll withholding requirements.

2015 Federal Budget - Impact on Immigration
Overall, with respect to immigration law, the Canadian government announced that it remains committed to reforming the Temporary Foreign Worker Program and ensuring that Canadians are first in line for available jobs.

Tax Insights: 2015 Federal budget: Good news for foreign employers with frequent business travellers to Canada
Foreign employers with non-resident employees temporarily working in Canada will welcome a 2015 federal budget proposal that provides relief from payroll withholding requirements.

Top global mobility issues facing tax directors - A seven-part Tax Tracks podcast series 
This podcast series is designed to provide Canadian corporate tax teams with a high-level understanding of issues impacting mobility programs to help them identify relevant corporate tax issues and areas of most risk.