Originally published March 2010
On March 4, 2010, the federal government tabled its Budget. This
bulletin summarizes the principal income tax measures affecting
businesses contained in the Budget.
A. TAX RATES
Budget 2010 contains no changes to corporate and personal tax
rates.
B. DOMESTIC CORPORATE TAXATION
SIFT Conversion and Loss Trading
Where control of a corporation is acquired, tax losses realized
by the corporation arising in a pre-acquisition of control period
may generally not be used to reduce tax payable in respect of a
post-acquisition of control period. A special rule in the
Income Tax Act (the "Act") generally deems an
acquisition of control of a corporation (and its subsidiaries) to
occur where the corporation issues shares in consideration for the
shares of a target corporation in a "reverse takeover",
e.g. where the shareholders of the target collectively receive
shares of the acquirer representing, in the aggregate, control of
the