Canada

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.

TEI Participates in Canadian Pre-Budget Consultations

On August 10, 2020, TEI submitted written recommendations to the Canadian House of Commons Standing Committee on Finance as part of its pre-budget consultations in advance of the 2021 federal budget.

TEI Holds 2019 Liaison Meetings with Canada Revenue Agency and Department of Finance

On December 10–11, 2019, a delegation of Canadian Income Tax Committee members assembled in Ottawa, Ontario, for TEI’s annual liaison meetings with representatives of the Canada Revenue Agency and Department of Finance.

TEI Comments on Proposed Changes to Canadian Tax Treatment of Employee Stock Options

On October 7, 2019, TEI submitted comments to the Department of Finance Canada concerning the income tax legislative proposals on employee stock options that were released for public consultation on June 17, 2019. TEI’s comments, reprinted below, were prepared by a cross-industry working group of Canadian Income Tax Committee members under the leadership of Kurtis L. Bond and Steve Saunders.