Tax Insights Publications

View this page in: Français

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


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: Deductibility of employee share plan costs: CRA's new guidance - what it means for you

The Canada Revenue Agency has revised its position on employer deductions for share plans that settle in stock.

Nova Scotia

On April 27, 2017, Nova Scotia's Finance and Treasury Board Minister, Randy Delorey, presented the province’s budget.

Ontario

On April 27, 2017, Ontario's Minister of Finance, Charles Sousa, presented the province’s budget.

Tax Insights: Common Reporting Standard becomes effective July 1, 2017 – Be ready

The Common Reporting Standard (CRS) for automatic information exchange becomes effective July 1, 2017, in Canada. To help you be ready, this Tax Insights discusses recent CRA and Organisation for Economic Co-operation and Development guidance concerning the Foreign Account Tax Compliance Act and the CRS.

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.

Manitoba

On April 11, 2017, Manitoba's Minister of Finance, Cameron Friesen, presented the province’s budget.

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: 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.

Quebec

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: 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: 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.

Saskatchewan

On March 22, 2017, Saskatchewan's Finance Minister, Kevin Doherty, presented the province’s budget.

2017 Federal Budget Analysis

This Tax Insights discusses the tax initiatives proposed in the 2017 Canadian federal budget.

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: 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: 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.

British Columbia

On February 21, 2017, British Columbia’s Minister of Finance, Michael de Jong, presented the province’s budget.

New Brunswick

On February 7, 2017, New Brunswick's Finance Minister, Cathy Rogers, delivered the province's budget.

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.

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: 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: 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 CRA released “Report on the Voluntary Disclosures Program,” which sets out recommendations of the Offshore Compliance Advisory Committee.

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.

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: CRA fishing net expands

The 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: 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 (CRA) has efficiently managed income tax objections.

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: 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: 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: 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: 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.”

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: 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: 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.

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: 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.

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 (TCC) 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: 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: 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.”

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 BC’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: Enhancing the CPP: What it means

On June 20, 2016, Canada’s Finance Ministers have agreed in principle to work on a Canada Pension Plan (CPP) enhancement that would be effective starting January 1, 2019.

Tax Insights: Sales tax changes coming soon – Are you ready?

Harmonized Sales Tax rates will increase in three provinces – New Brunswick, Newfoundland and Labrador, and Prince Edward Island – in 2016. To be ready, businesses with operations or customers in these provinces should consider how they will be affected.

Tax Insights: SCC strikes down Minister’s authority to demand records subject to privilege

Two recent Supreme Court of Canada 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: 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 input tax credits 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 HST increase – Transitional rules released – Be ready

Newfoundland and Labrador’s April 14, 2016 budget increases the provincial component of Harmonized Sales Tax, on July 1, 2016, from 8% to 10%, resulting in an HST rate of 15%.

Tax Insights: 2016 Manitoba budget – Tax highlights

On May 31, 2016, Manitoba’s Minister of Finance, Cameron Friesen, presented the province’s budget

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.

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: 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.

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: 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: 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: 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.

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.

2016 Federal Budget - Instant Reactions

Our reactions and insights to the Federal Budget, are available here.

2016 Federal budget

This Tax Insights discusses the tax initiatives proposed in the budget.

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: 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). Depending on your province or territory of residence, you can reduce your tax liability by up to 54% of the total amount you donate to registered charities in a year exceeding $200.

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: 2016 Ontario budget – Tax highlights

On February 25, 2016, Ontario’s Minister of Finance, Charles Sousa, presented the province’s budget.

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: 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: 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: 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: 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: 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: 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: 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 – 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 – 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: 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: 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: 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