Canadian Income Tax

TEI’s Canadian Income and Commodity Tax Committees Seek Member Input for 2021 Liaison Meetings

The members of TEI’s Canadian Income Tax and Canadian Commodity Tax committees are actively preparing for the Institute’s 2021 liaison meetings in Ottawa, and they seek your input in developing this year’s meeting agendas.

CANADIAN INCOME TAX

Staff Liaison:

Ben Shreck, Tax Counsel
202.464.8353

 

TEI Participates in Canadian Income Tax Mandatory Disclosure Rules Consultation

On April 5, 2022, TEI submitted written comments to the Department of Finance concerning the government’s newly released draft legislative proposals to amend Canada’s income tax mandatory disclosure rules.  These proposals were initially described in the federal budget documents tabled in Canada’s House of Commons on April 19, 2021 (“Budget 2021”), on which TEI provided preliminary feedback last fall.  Consistent with our e

TEI Participates in Consultation on Canada’s Proposed Excessive Interest and Financing Expenses Limitation

On May 6, 2022, TEI submitted written comments to the Department of Finance concerning the government’s newly released draft legislative proposals to limit the amount of interest and other financing expenses that businesses may deduct for Canadian income tax purposes.  These proposals were initially described in the federal budget documents tabled in Canada’s House of Commons on April 19, 2021 (“Budget 2021”), on which TEI provi

TEI Comments on the Proposed Implementation of Pillar Two (Global Minimum Tax) in Canada

On July 21, 2022, TEI submitted preliminary comments to the Department of Finance concerning the Government of Canada’s proposal to implement Pillar Two of the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (“BEPS”) two-pillar plan for international tax reform, as contemplated by the federal budget documents tabled in Canada’s House of Commons on April 7, 2022 (“Budget 2022”).  TEI’s comments highlight several

TEI Applies for Leave to Intervene (as Amicus Curiae) in Deans Knight Income Corporation v. The Queen

On June 30, 2022, TEI applied for leave to intervene (as amicus curiae) in Deans Knight Income Corporation v.

TEI Comments on Proposed Interest Deductibility Limits in Canadian Budget 2021

On December 29, 2021, TEI submitted comments to the Department of Finance Canada concerning the government’s proposal to introduce a new limitation on the deduction of business interest expense, as described in Budget 2021.  Generally speaking, the proposal would limit the amount of net interest expense that a corporation could deduct in computing its taxable income to a fixed share of the corporation’s earnings.

TEI Holds 2021 Virtual Liaison Meetings with Canada Revenue Agency and Department of Finance

On December 7-8, 2021, delegations of Canadian Income Tax Committee and Canadian Commodity Tax Committee members virtually participated in TEI’s annual liaison meetings with representatives of the Canada Revenue Agency (“CRA”) and Department of Finance.

TEI Comments on Proposed Changes to Canada’s Income Tax Mandatory Disclosure Rules

On December 10, 2021, TEI submitted comments to the Department of Finance concerning the proposed changes to Canada’s income tax mandatory disclosure rules described in Budget 2021. TEI’s comments focus primarily on the government’s proposals to amend the Income Tax Act’s reportable transaction rules and introduce a new requirement for specified corporations to proactively report uncertain tax positions to the Canada Revenue Agency.

TEI Holds 2020 Virtual Liaison Meetings with Canada Revenue Agency and Department of Finance

On December 8–9, 2020, delegations of Canadian Income Tax Committee and Canadian Commodity Tax Committee members virtually participated in TEI’s annual liaison meetings with representatives of the Canada Revenue Agency (“CRA”) and Department of Finance.
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