Revisions to earlier draft legislation on the Excessive Interest and Finance Expenses Limitation (EIFEL) regime were released by the Department of Finance on November 3, 2022. Lawson Lundell submitted comments on the government’s first round of consultations, raising concerns about the overly broad scope of the rules. A copy of our earlier submission can be found at ...
On February 4, the federal government put forward draft legislation setting out the new Excessive Interest and Financing Expenses Limitation (EIFEL) regime. EIFEL is intended to prevent erosion of the Canadian tax base by limiting net interest and financing deductions of certain Canadian taxpayers generally to 30% of earnings before interest, taxes, depreciation and ...
Most taxation is concerned with raising revenue for government expenditure in the short term (typically within a year or so of the taxable event). A well-designed modern tax will also typically involve a withholding mechanism: think, for example, of payroll withholding on wages or the charge / input tax credit system in a typical VAT, such as Canada’s GST. The Digital ...
The enforcement by Canada Revenue Agency (“CRA”) of its super priority position for deemed trust liabilities has long been an issue of uncertainty for secured creditors. While the Excise Tax Act (the “ETA”) has carved out “prescribed security interests” from that super priority, the calculation of the funds that continue to rank in priority to a prescribe ...
Due to the recent economic shock of the COVID-19 pandemic, many businesses are considering various options to weather the economic shock. One commonly considered option is to ask existing creditors to forgive all or part of a debt. However, this strategy is subject to a complex regime commonly known as the “debt forgiveness rules”. These rules can trigger important ...
The 2016 Federal Budget was released March 22nd. The overarching theme is to provide increased benefits and relief to middle-class individuals and to close or restrict cross-border tax planning. Highlights include:
Income Tax
Increased Individual Marginal Tax Rates
As part of Bill C-2 tabled on December 9, 2015, the federal government announced an increase to the top ...
The BC Budget (tabled on February 17, 2015) contained no major announcements and no general corporate or personal tax rate changes. Nonetheless, it provides opportunity for personal tax planning for high rate tax payers, and extends useful assistance to early stage businesses in BC.
Personal
The combined top rate of BC tax is 45.8% (16.8% of BC tax + 29% of Federal tax). The ...
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