Tax Insights Publications

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Our new periodic newsletter, Tax Insights, will keep you up-to-date on a broad range of corporate and personal tax issues.

Tax Insights: Ontario Retirement Pension Plan coming 2017 – Get ready

The Ontario Retirement Pension Plan will be phased in starting January 1, 2017. To get ready, employers should determine whether they will be required to make contributions.

Tax Insights: 2016 New Brunswick budget – Tax highlights

On February 2, 2016, Finance Minister, Roger Melanson, delivered New Brunswick's 2016 budget.

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: 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.

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: 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.

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.

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.

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 – 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 – 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 – US estate tax exposure for Canadians (2016 edition)

This Tax Insights considers the exposure of Canadian residents to US estate tax.

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 – 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 – 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: 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.

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: 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 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: 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: 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: 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.

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: Do you insure your Canadian operations with offshore insurers? If so, you may be liable for tax!

This Tax Insights focuses on the Alberta insurance premiums tax, but also considers taxes imposed by other provinces and the territories relating to offshore insurance, which can include insurance purchased through a broker or insurer outside a province or territory, and the federal excise tax.

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: 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.

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: 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.

Tax Insights: CBSA announces Phase 2 2015 audit priorities – What they mean for importers

The Canada Border Services Agency (CBSA) 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: 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, some of which Kruger had written, and others it had purchased. Kruger also submitted that it held the options as inventory and could therefore carry them at fair market value.

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: 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.

Tax Insights: 2015 Manitoba budget – Tax highlights

On April 30, 2015, Manitoba’s Finance Minister, Greg Dewar, 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: 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.

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: Reporting requirements for Canadians holding stock options in foreign corporations – Ensure you comply

The CRA recently issued a technical interpretation that clarifies the reporting requirements for Canadian employees who hold awards to acquire shares in foreign corporations. Ensure you comply to avoid penalties.

Tax Insights: Reporting obligations for labour organizations – Possible changes

Draft legislation – introduced as a Private Member’s Bill – would significantly expand the information that labour organizations (including labour trusts) must report to the Canada Revenue Agency.

Tax Insights: 2015 Annual tax filing and remittance deadlines for corporations

This <em>Tax Insights</em> outlines some of the more common corporate compliance requirements to be considered at this time of year.

Tax Insights: Consequences of a weak Canadian dollar: Transactions involving foreign affiliates

With the substantial depreciation of the Canadian dollar against its American counterpart, many taxpayers have accrued foreign exchange gains or losses on assets or liabilities denominated in US dollars.

Tax Insights: GST/HST alert: Reinsurance premiums paid to non-resident related parties — An update

The Department of Finance has clarified its “policy intent” for determining the amount of GST/HST that is payable by Canadian-resident insurers on reinsurance premiums paid to non-arm’s length non-resident insurers.

Tax Insights: Valuation adjustments after importation: Bad and good news for importers

The Canada Border Services Agency (CBSA) recently significantly changed its policy with respect to downward price adjustments and how they apply to declared value calculations for imported goods.

Tax Insights: QST tax alert for investment plan managers: Act now to fix reporting errors

Investment plan managers may need to act now to fix QST reporting errors. This affects investment plan managers that made tax transfer adjustment elections for GST/HST purposes with investment plans that allow the manager to effectively charge the plans a “blended rate” of GST/HST throughout the year.

Tax Insights: CBSA announces Phase 1 2015 audit priorities: What they mean for importers

The Canada Border Services Agency (CBSA) recently released its Phase 1, 2015 national trade verification (Audit) priorities. Phase 2, 2015 Audit priorities, will be released summer of 2015.

Tax Insights – GST/HST and QST alert: Structuring management fee rebates and distributions

The Tax Court of Canada’s recent decision in Invesco Canada Ltd. confirms that asset managers can structure fee arrangements with mutual fund trusts and institutional investors in a manner which only requires the asset manager to collect GST/HST (or QST) on the net management fee that is payable by the mutual fund trust to the manager.

Tax Insights: Canadian importers face higher customs duties – General Preferential Tariff (GPT) treatment ends for 72 countries

On January 1, 2015, the Canadian federal government withdrew the General Preferential Tariff (GPT) treatment benefits from 72 developing countries (including China) on imports into Canada. As a result, Canadian importers may now be paying more duty on certain imports.

Tax Insights: Trading with Russia – Sanctions broadened for Canadian businesses in the oil exploration and production sector

On December 19, 2014, the Canadian government amended the Special Economic Measures (Russia) Regulations to broaden Canada’s trade sanctions against Russia.

Tax Insights: TCC rules in taxpayer’s favour in SR&ED case (Les Abeilles)

On October 23, 2014, the Tax Court of Canada (TCC) released its decision in <strong>Les Abeilles Service de Conditionnement Inc</strong> (in French only). The TCC overturned the Canada Revenue Agency’s position that the four projects under dispute were not scientific research and experimental development.

Fall 2014 Economic and financial update – Quebec

Minister of Finance Carlos Leitão presented his Fall 2014 Economic and Financial Update and states that the government action will help restore sound public finances in Québec.

Tax Insights: Outstanding legislative tax proposals announced before April 1, 2013 – Where do they stand?

As required by Canada’s Financial Administration Act, the Department of Finance recently provided Parliament a list of tax proposals that were announced before April 1, 2013, but have not yet been passed into law.

Tax Insights: GST/HST and QST elections for nil consideration – Form will have to be filed!

The GST/HST and QST rules allow members of closely related groups to elect to treat certain taxable supplies made between the members as being made for nil consideration, if certain conditions are met. Generally, making this election gives the group a cash flow benefit.

Tax Insights: GST/HST and QST alert – Investors must issue notification of investor percentages – November 15, 2014 deadline

Distributed investment plans are required to obtain information from investors to determine the plan’s provincial attribution percentage, so that the plan's GST/HST liabilities can be calculated in accordance with the selected listed financial institution GST/HST reporting rules.

Tax Insights: Regulation 102 processes – What has changed?

Employers who send employees to work in Canada must comply with Canadian payroll regulations. This can involve various processes, such as applying for Canadian tax identification numbers and for tax withholding waivers, remitting taxes and issuing T4 slips.

Tax Insights: The new Extractive Sector Transparency Measures Act: What it means for you

The Extractive Sector Transparency Measures Act requires public disclosure of government payments made by mining and oil & gas entities engaged in the commercial development of oil, gas and minerals.

Tax Insights: Income-splitting and other tax measures for families introduced

Today, the federal government introduced three income tax measures intended to relieve the tax burden for families.

Tax Insights: British Columbia releases the Liquefied Natural Gas (LNG) Income Tax Act

Today, British Columbia introduced the much-awaited Liquefied Natural Gas Income Tax Act (the LNG Act) which provides important new details, including a reduction in the tax rates, an investment allowance for computing net operating income subject to tax, complex transfer pricing rules and deeming provisions.

Tax Insights: Trust loss restriction rules – Proposed amendments

On October 20, 2014, the Department of Finance released a Notice of Ways and Means Motion to implement tax relief measures that include proposed amendments to the “trust loss restriction rules.”

Tax Insights: Good news for US taxpayers with RRSPs or RRIFs

A recent US Internal Revenue Service announcement (Rev. Proc. 2014-55) makes it easier for Americans and Canadians who hold interests in registered retirement savings plans or registered retirement income funds to get favourable US tax treatment.

Tax Insights: Recommendations on countering treaty abuse – Where are we now?

This Tax Insights provides an overview of recent OECD/G20 and domestic initiatives that review and recommend approaches to counter treaty abuse, including “treaty shopping.”

Tax Insights: New tax rules for testamentary trusts – The bad and the good (and some surprises)

Draft legislative proposals released by the Department of Finance on August 29, 2014, have important implications for estates and testamentary trusts, and for post mortem tax planning.

Tax Insights: GST/HST reporting for the real estate sector: Are you compliant?

The Canada Revenue Agency is auditing the GST/HST reporting of taxpayers in the real estate sector.

Tax Insights: The snowbirds sing… and the IRS listens

For many Canadians, the opportunity to avoid a harsh winter by fleeing to the southern United States is irresistible. But some may have overlooked important tax implications.

2014 Ontario budget: Higher taxes for higher earners and some corporations

On July 14, 2014, Ontario’s Minister of Finance, Charles Sousa, presented the majority government's budget. The July 14, 2014 budget reintroduces the tax measures proposed in the province’s May 1, 2014 budget.

Tax Insights: More changes to Form T1135, ‘Foreign Income Verification Statement’

The CRA has announced changes for taxpayers required to file Form T1135, ‘Foreign Income Verification Statement.’

Tax Insights: GST/HST pension plan compliance obligations

This Tax Insights discusses Goods and Services Tax/Harmonized Sales Tax compliance issues relevant to employers that have registered pension plans.

Tax Insights: Structuring a partnership: CRA attacks GST/HST-exempt treatment of partnership distributions

Incorrectly structuring the activities of a partnership can cause GST/HST deeming rules to apply; resulting in a GST/HST liability for person’s involved in the partnership’s business.

Tax Insights: New IRS relief for US citizens living outside the US

On June 18, 2014, the US Internal Revenue Service announced changes to its offshore voluntary compliance programs that are expected to significantly increase the number of US persons that can participate in these programs.

Tax Insights - June 2014 Quebec budget

The Minister of Finance Carlos Leitao, tabled a budget mainly aimed at economic recovery and restoring sound public finances.

Tax Insights: June 2014 Quebec budget – Tax highlights

Carlos Leitao, Quebec Minister of Finance, delivered today, June 4, 2014, the 2014/2015 Budget of the Government of Quebec.

Tax Insights: GST/HST issues affecting the real estate and construction industries

This Tax Insights highlights Goods and Services Tax/Harmonized Sales Tax (GST/HST) issues relevant to the real estate and construction industries.

Tax Insights: Federal Court rules on 95(6)(b) in Lehigh

On April 23, 2014, the Federal Court of Appeal (FCA) released an important decision on the scope of paragraph 95(6)(b), an anti avoidance rule found in the part of the Income Tax Act that governs the tax treatment of ‘foreign affiliates’ of Canadian corporations.

Tax Insights: Alert for multinational companies: Payroll and immigration compliance

Cross-border employee travel into Canada raises various Canadian tax withholding and immigration compliance requirements. Multinational companies should consider whether they have the processes and controls in place to manage these requirements and the associated risks.

Tax Insights: Tax Court of Canada finds corporate reorganization abuses section 84.1

In a judgment (Descarries) rendered on March 7, 2014, under the Informal Procedure, the Tax Court of Canada provided an example of a situation where, in the Court’s view, the object and spirit of section 84.1 had been abused, triggering the application of the general anti-avoidance rule (GAAR).

Tax Insights: 2014 Manitoba budget: Tax highlights

On March 6, 2014, Manitoba’s Minister of Finance, Jennifer Howard, presented the province’s budget.

Tax Insights: Foreign Income Verification Statement (Form T1135) – Transitional rules announced

Taxpayers required to file Form T1135, Foreign Income Verification Statement, must include additional information on foreign property, starting for taxation years ending after June 30, 2013.

Tax Insights: 2014 Quebec budget

Budget 2014-2015 confirms a return to fiscal balance in 2015-2016.

Tax Insights: 2014 Quebec budget – Tax highlights

Nicolas Marceau, Quebec Minister of Finance, delivered today, February 20, 2014, the 2014-2015 Budget of the Government of Quebec.

Tax Insights: 2014 federal budget: The demise of immigration trusts

Canada’s February 11, 2014 federal budget proposes to eliminate the tax benefits of immigration trusts. If you have relocated to Canada, this change could have adverse tax consequences.

Tax Insights: 2014 British Columbia budget - Tax highlights

On February 18, 2014, British Columbia’s Minister of Finance, the Honourable Michael de Jong, presented the province’s budget.

Tax Insights: British Columbia unveils its liquefied natural gas (LNG) tax

Today, British Columbia’s budget unveiled its much-anticipated liquefied natural gas (LNG) tax regime.

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.

Tax Insights: 2014 Federal budget: How it affects you and the charitable and not-for-profit sector

This Tax Insights considers proposals in Canada’s February 11, 2014 federal budget that affect the charitable and not-for-profit sector.

Tax Insights: Bare trusts, nominees and joint ventures: Temporary administrative leniency

A recent Canada Revenue Agency announcement grants taxpayers a temporary reprieve for a bare trust or nominee that reports the Goods and Services Tax/Harmonized Sales Tax on behalf of the members of a joint venture.

2014 Federal budget: More tightening, few tax breaks

Read our analysis of the 2014 federal budget to learn about the tax implications for you.

Tax Insights: Trust loss restriction rules: Implications for funds and asset managers

Newly enacted trust loss restriction rules may have unintended and adverse tax implications for investment funds established as trusts.

Tax Insights: 2014 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.