INTRODUCTION
Parliament has enacted legislation adopting the Canada Emergency
Wage Subsidy (CEWS) through amendments to the Income Tax
Act (ITA). Although the CEWS program is not tax legislation,
by implementing the CEWS through the ITA, the government sought to
leverage existing income tax systems to distribute the subsidy to
employers in a timely manner and to utilize the broad investigative
powers and penalty provisions of the ITA to verify and encourage
compliance with the terms of the program.
The CEWS, which was adopted on April 11, 2020, is intended to
support businesses in their efforts to continue to employ their
employees during the COVID-19 pandemic by enabling qualifying
entities to obtain an emergency wage subsidy from the federal
government. The program is generally intended to provide a
subsidy of 75% of eligible remuneration paid to eligible employees,
up to $847 per week, per employee. Special rules exist with respect
to remuneration paid to