Although to most of the world the federal Budget tabled on
February 11, 2014 (the "Budget") may have seemed to be of
limited consequence, there are many tax practitioners and clients
who will be significantly impacted by its content. From painful
changes to the taxation of estates, to the elimination of immigrant
trust planning, severe restrictions on both the offshore regulated
"bank" exception and captive insurance programs, as well
as a host of pending tightening measures that will impact
multinational enterprises and the use of treaties, tax planners
will definitely have their hands full.
However, for my clients, I see the biggest impact coming from
the proposed consultation process to make changes to the taxation
of eligible capital property ("ECP"). While at first
glance, a move to coordinate the current ECP regime (the
"Current Regime") with the existing capital cost
allowance regime seems completely logical and relatively
innocuous,1 it is the change to how
