The Department of Finance Canada on Friday released draft legislative proposals for public comment relating to certain income tax measures announced in Budget 2018 that haven’t already been legislated.

These proposals would implement measures respecting:

  • improving access to the Canada Workers Benefit;
  • the reporting requirements for trusts;
  • passive income — the allocation rule for losses applied against Part IV of the Income Tax Act, Tax on Taxable Dividends Received by Private Corporations
  • reassessment periods — requirements for information and compliance orders;
  • reassessment periods — non-resident non-arm’s length persons;
  • the sharing of information relating to criminal matters
  • the deductibility of employee contributions to the enhanced portion of the Quebec Pension Plan;
  • artificial losses using equity-based financial arrangements;
  • the stop-loss rule on share repurchase transactions;
  • the at-risk rules for tiered partnerships;
  • cross-border surplus stripping using partnerships and trusts; and
  • foreign affiliate proposals relating to investment businesses, controlled foreign affiliate status, trading or dealing in indebtedness, reassessments and reporting requirements.

The draft legislation also includes proposals related to sales and excise tax matters.

The comment period for these matters ends Sept. 10. An accompanying consultation on the matter of GST/HST holding corporation rules ends Sept. 28.

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