Canada

TEI Holds 2023 Liaison Meetings with Canada Revenue Agency and Department of Finance

On December 5-6, 2023, a delegation of the Canadian Commodity Tax Committee members participated in TEI's annual liaison meetings with representatives of the Canada Revenue Agency (“CRA”) and Department of Finance. The 2023 meetings featured robust agendas covering a range of tax law, policy, and administration issues of importance to many TEI members. Official written responses to many of TEI’s questions are expected from CRA.

Canadian Pillar Two Implementation - TEI Comments

On September 29th, TEI submitted comments to the Canadian Department of Finance regarding its proposed legislation to implement Pillar Two of the OECD's project on the taxation of the digitalization of the economy. Canada's legislation, entitled the Global Minimum Tax Act, encompasses most, but not all, of the necessary Pillar Two rules for Canada to comply with the global minimum tax regime.

Canadian Bare Trust Reporting - TEI Comments

On September 27th, 2023, TEI submitted comments to the Canada Revenue Agency regarding new rules for reporting "bare trusts arrangements." TEI's comments focused on the compliance burden the new rules would impose on corporations and other businesses, which in most cases would be duplicative of other reporting requirements already imposed on such entities, among other things. TEI's comments were prepared by its Canadian Income Tax Committee, whose Chair is Steve Saunders of Atco. Benjamin R. Shreck, TEI Tax Counsel, coordinated the preparation of TEI's comments.

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 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 Supports Deans Knight Income Corporation's Application for Leave to Appeal

On October 1, 2021, TEI issued a letter in support of the taxpayer’s application for leave to appeal to the Supreme Court of Canada in Deans Knight Income Corporation v. Her Majesty the Queen.

TEI Comments on Canadian Government’s Proposed Digital Services Tax

On June 18, TEI submitted comments to the Canadian Department of Finance regarding the Canadian Government’s proposed tax on digital services (the DST). TEI’s comments focused on the practical compliance issues businesses will face should the proposed tax be enacted into law.

TEI Comments on Canadian Government’s Fall Economic Statement

On January 29, TEI submitted comments to the Canadian Department of Finance regarding certain items in the Department’s fall economic statement, including issues related to proposed new rules on cross border digital products and services, as well as goods supplied through fulfillment warehouses.

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.

TEI Members Provide Feedback on CRA Draft of Simplified Form T2200, Declaration of Conditions of Employment for Working at Home During COVID-19

On September 15, 2020, following an intensive effort to survey TEI members working for companies in different industries across Canada, TEI’s Canadian Income Committee submitted a compilation of responsive, actionable comments to the CRA concerning the draft form.
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