Canada Emergency Wage Subsidy: As enacted, extended and proposed to be amended
Updated on May 19, 2020 To encourage businesses to retain their employees during the COVID-19 pandemic, Parliament convened on an emergency basis on April 11, 2020 to enact Bill C-14, which legislates the Canada Emergency Wage Subsidy (the “CEWS”). Details […]
Foreign Affiliate Dumping Transactions
Anti-Surplus Stripping Rule for Canadian Resident Corporations Controlled by Non-Residents Bill C-45 adds a new anti-surplus stripping rule to the Income Tax Act (Canada) (the “Act”) as section 212.3. This provision will apply to a corporation that is: resident in […]
Pertinent Loan or Indebtedness Regime
IN THIS SECTION: PLOI Relieving Rule for Subsection 15(2) Shareholder Indebtedness Scope of PLOI Exception PLOI Elections Certain Reorganizations Involving Canadian Resident Corporate Creditors Deemed Interest Income To File or Not to File a PLOI Election? Application Date PLOI Relieving […]
Federal Budget Review
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Upstream Loans and Other Indebtedness to Foreign Affiliates
Draft legislation making significant changes to the foreign affiliate provisions of the Income Tax Act (Canada) (the “Act”) was released by the Department of Finance on August 19, 2011. The new provisions deal with upstream loans from and other indebtedness […]
