TEI Participates in Canadian Income Tax Mandatory Disclosure Rules Consultation
On April 5, 2022, TEI submitted written comments to the Department of Finance concerning the government’s newly released draft legislative proposals to amend Canada’s income tax mandatory disclosure rules. These proposals were initially described in the federal budget documents tabled in Canada’s House of Commons on April 19, 2021 (“Budget 2021”), on which TEI provided preliminary feedback last fall. Consistent with our earlier submission, the enclosed comments focus intently on the perceived overbreadth of the draft proposals along with the immense compliance and administration
TEI Participates in Consultation on Canada’s Proposed Excessive Interest and Financing Expenses Limitation
On May 6, 2022, TEI submitted written comments to the Department of Finance concerning the government’s newly released draft legislative proposals to limit the amount of interest and other financing expenses that businesses may deduct for Canadian income tax purposes. These proposals were initially described in the federal budget documents tabled in Canada’s House of Commons on April 19, 2021 (“Budget 2021”), on which TEI provided preliminary comments last December. Consistent with our earlier submission, the enclosed comments raise a range of concerns with the draft legislation
TEI Comments on the Proposed Implementation of Pillar Two (Global Minimum Tax) in Canada
On July 21, 2022, TEI submitted preliminary comments to the Department of Finance concerning the Government of Canada’s proposal to implement Pillar Two of the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (“BEPS”) two-pillar plan for international tax reform, as contemplated by the federal budget documents tabled in Canada’s House of Commons on April 7, 2022 (“Budget 2022”). TEI’s comments highlight several areas of significant, widespread concern with the plan’s implementation in Canada, as contemplated by Budget 2022, that warrant further and careful attention.
TEI Applies for Leave to Intervene (as Amicus Curiae) in Deans Knight Income Corporation v. The Queen
On June 30, 2022, TEI applied for leave to intervene (as amicus curiae) in Deans Knight Income Corporation v.
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 Holds 2021 Virtual Liaison Meetings with Canada Revenue Agency and Department of Finance
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.