Category: Tax
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Federal Bill C-13 re COVID-19 Emergency Measures
Federal Bill C-13, An Act respecting certain measures in response to COVID-19, received Royal Assent on March 25, 2020. Bill C-13 includes economic relief for businesses and individuals, as well as amendments to the leave of absence provisions in the Canada Labour Code . . .
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CRA Actuarial Bulletin re Apportioning Assets and Actuarial Liabilities
The Canada Revenue Agency has published a draft Actuarial Bulletin No. 4: Apportioning Assets and Actuarial Liabilities . . .
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Federal Government Delays Changes to Stock Options
Earlier this year, the federal government tabled a Notice of Ways and Means Motion to limit the benefit of employee stock option deductions for high-income individuals employed at large, long-established, mature organizations . . .
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Canada (Attorney General) v. British Columbia Investment Management Corp., 2019 SCC 63 – Appeal re Taxation of Public Sector Plan Dismissed
Under the Constitution Act, 1867, provincial governments and their agents are immune from federal taxation when acting within their legislated mandates. The British Columbia Investment Management Corporation (bcIMC), which was established under the B.C. Public Sector Pension Plans Act (PSPPA) as a Crown trust corporation to provide certain trust business and investment management services to various B.C. public sector pension plans, enjoyed that constitutional immunity . . .
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CRA 2020 Retirement Savings Limits
CRA has posted the annual money purchase (MP), defined benefit (DB), registered retirement savings plan (RRSP), deferred profit sharing plan (DPSP) and the tax-free savings account (TFSA) limits, as well as the year’s maximum pensionable earnings (YMPE . . .
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Federal Draft Tax Proposals Include Pensions
The federal government has published draft amendments to the Income Tax Act, which were announced in this year's budget. The amendments include changes related to annuities, specified multi-employer plans and individual pension plans . . .
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Federal Notice of Ways & Means Motion re Stock Options
Further to this year's Budget announcement, the federal government tabled a Notice of Ways and Means Motion on stock options. The changes are intended to limit the benefit of employee stock option deductions for high-income individuals employed at large, long-established, mature organizations . . .
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Federal Draft ITA Amendments re Conversion of Health and Welfare Trusts
The federal government has published draft amendments to the Income Tax Act (ITA) to facilitate the conversion of existing Health and Welfare Trusts (HWT) to Employee Life and Health Trusts (ELHT) and to improve the rules applicable to ELHTs . . .
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Viterra Inc. v. Canada, 2019 FCA 55 – Appeal of GST Reassessment of Plan Administrator Continues
Saskatchewan Wheat Pool (SWP) engaged third party investment managers to provide investment services for its defined benefit plans. In 2007 and 2008, the Canada Revenue Agency (CRA) denied SWP’s input tax credit (ITC) claims on the GST paid to the investment managers, because “SWP did not acquire the Investment Services for consumption, use or supply in the course of SWP’s commercial activities . . .
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Mammone v. Canada, 2019 FCA 45 – CRA Correction of Notice of Plan Revocation is Too Late for Taxpayer Reassessment
When Mammone retired in 2009, he established a new pension plan, of which he was the sole member (ie., an individual pension plan), and transferred the commuted value of his pension benefit from OMERS to the new pension plan . . .
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