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: 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: 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: 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: 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: 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: 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 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.

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: 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: 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: 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

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: 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: 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 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: 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 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 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 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.

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.