Global Daily Tax News, Canada To Implement Various Previously Discussed Tax Reforms, (Dec 26, 2024)

Canada's recently released 2024 Fall Economic Statement included confirmation from the Government of its intention to proceed with numerous previously announced tax and related measures, as modified to take into account consultations and deliberations since their release.

These measures include:

• Legislative proposals included in the notice of ways and means motion tabled on October 29, 2024, related to charities and reproductive services;

• Legislative proposals included in the notice of ways and means motion tabled on September 23, 2024, related to capital gains and the lifetime capital gains exemption;

• Legislative and regulatory proposals released on August 12, 2024, including with respect to the following measures:

  • Canadian Entrepreneurs' Incentive;

  • Alternative Minimum Tax;

  • Disability Supports Deduction;

  • Employee Ownership Trust Tax Exemption;

  • Worker Cooperatives;

  • Charities and Qualified Donees;

  • Registered Education Savings Plans;

  • Non-Compliance with Information Requests;

  • Avoidance of Tax Debts;

  • Mutual Fund Corporations;

  • Synthetic Equity Arrangements;

  • Manipulation of Bankrupt Status;

  • Accelerated Capital Cost Allowance for Productivity-Enhancing Assets;

  • Accelerated Capital Cost Allowance for Purpose-Built Rental Housing;

  • Interest Deductibility Limits;

  • Withholding for Non-Resident Service Providers;

  • Substantive CCPCs;

  • Regulations related to the application of the enhanced (100-per-cent) GST Rental Rebate to qualifying co-operative housing corporations;

  • Technical amendments relating to the GST/HST, excise levies and other taxes and charges announced in the August 12, 2024, release;

  • Clean Electricity Investment Tax Credit;

  • Proposed expansion of eligibility for the Clean Technology investment tax credit to support generation of electricity and heat from waste biomass;

  • Proposed expansion of eligibility for the Clean Technology Manufacturing investment tax credit to support Polymetallic Extraction and Processing;

  • Other changes related to the Clean Economy Investment Tax Credits;

  • The Global Minimum Tax Act and the Income Tax Conventions Act; and

  • Technical tax amendments to the Income Tax Act and the Income Tax Regulations;

• Legislative proposals released on July 12, 2024, related to implementing an opt-in Fuel, Alcohol, Cannabis, Tobacco and Vaping (FACT) value-added sales tax framework for interested Indigenous governments;

• The Crypto-Asset Reporting Framework and the Common Reporting Standard announced in Budget 2024;

• The proposed exemption from the Alternative Minimum Tax for certain trusts for the benefit of Indigenous groups announced in Budget 2024;

• Legislative and regulatory proposals announced in Budget 2024 with respect to a new importation limit for packaged raw leaf tobacco for personal use;

• Legislative and regulatory proposals announced in the 2023 Fall Economic Statement with respect to the GST/HST joint venture election rules;

• Regulatory proposals released on November 3, 2023, to temporarily pause the federal fuel charge on deliveries of heating oil;

• Legislative proposals released on August 4, 2023, including with respect to the following measures:

  • Technical amendments to GST/HST rules for financial institutions;

  • Tax-exempt sales of motive fuels for export;

  • Revised Luxury Tax draft regulations to provide greater clarity on the tax treatment of luxury items; and

  • Technical tax amendments to the Income Tax Act and the Income Tax Regulations.

• Legislative amendments to implement changes discussed in the transfer pricing consultation paper released on June 6, 2023;

• Legislative proposals released on August 9, 2022, including with respect to the following measures:

  • Technical amendments to the Income Tax Act and Income Tax Regulations; and

  • Remaining legislative and regulatory proposals relating to the GST/HST, excise levies and other taxes and charges announced in the August 9, 2022, release.

• Legislative amendments to implement the Hybrid Mismatch Arrangements rules announced in Budget 2021.

• The income tax measure announced on December 20, 2019, to extend the maturation period of amateur athlete trusts maturing in 2019 by one year, from eight years to nine years;

• Legislative amendments to give effect to the suspension of the Agreement Between the Government of Canada and the Government of the Russian Federation for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and on Capital under domestic law as of November 18, 2024.

The 2024 Fall Economic Statement also reaffirms the government's commitment to move forward as required with other technical amendments to improve the certainty and integrity of the tax system.