ARTICLE · 01 MARCH 2018

The Stikeman Elliott Federal Budget Commentary 2018

Stikeman Elliott LLP

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On July 18, 2017, the government indicated that there were three aspects of the taxation of private corporations that, while legal, were unfair to the undefined "middle class".

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PRIVATE CORPORATIONS WIN 2 - 1 IN QUADRUPLE OVERTIME

Highlights

Business Tax Measures

Substantial pullback on passive income proposals
Additional rules to prevent the realization of "artificial" losses by financial institutions
Green v. R. (FCA) overturned – limited partnership losses trapped in tiered partnerships

International Tax Measures

Extension of cross-border surplus stripping rule to partnerships and trusts
Foreign affiliate amendments to shutdown "tracking arrangements"

Sales and Excise Tax Measures

Minor modifications to previous proposals in respect of GST/HST on management services provided to "investment limited partnerships"

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