The story began on July 18, 2017, when the Liberal Government
announced proposed tax changes that intended to fundamentally and
adversely alter the taxation of income derived from private
corporations (please refer to Crowe Soberman's summary of these
proposals
here). A 75-day consultation period followed (in the peak of
summer) and practitioners rushed to submit their comments to the Department of
Finance expressing their concerns regarding the proposals. This
consultation period ended on October 2, 2017, and it is reported
that the Department of Finance received more than 21,000
submissions. Only 10 days later, during the week of October 16, the
Department of Finance announced that they would not be moving ahead
with the proposals that would have curtailed the multiplication of
the capital gains exemption and surplus stripping transactions. At
that time, the Department of Finance also announced that it would
be moving forward with the proposals relating to limiting
