ARTICLE · 16 JANUARY 2018

Private Corporation Announcements, October 16-20, 2017

Moodys Private Client Law LLP

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After a flurry of submissions—more than 21,000—to the Department of Finance regarding the July 18, 2017 private corporation tax proposals, the minister of finance made a number of announcements between October 16 and 20.

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After a flurry of submissions—more than 21,000—to the Department of Finance regarding the July 18, 2017 private corporation tax proposals, the minister of finance made a number of announcements between October 16 and 20. These announcements are summarized below.

Proposals to limit access to the lifetime capital gains exemption. The government announced that it was no longer moving forward with the measures that would have significantly limited access to the lifetime capital gains exemption. Does this mean that access to the exemption will be prevented vis-à-vis the new income-splitting proposals under section 120.4 if a taxable capital gain realized by a shareholder of a CCPC would fail the new reasonableness tests? At the recent Canadian Tax Foundation conference ("Tax Planning Using Private Corporations: Analysis and Discussion with Finance," held in Ottawa on September 25, 2017), a Department of Finance representative appeared to offer some clarity on this

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