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ARTICLE · 21 APRIL 2021

The Stikeman Elliott Federal Budget Commentary 2021

For months, there has been widespread speculation as to the measures that Budget 2021 would introduce, given that it has been more than two years since the last federal budget and the ...

CanadaTax

The more things change, the more they stay the same

Highlights

Business Income Tax Measures

  • Limitations on Interest Deductibility
    • Limiting net interest expense to a fixed ratio of "tax EBITDA"
  • Mandatory Disclosure Rules
    • Broadening the scope of what constitutes a "reportable transaction"
    • Implementing a mandatory disclosure regime whereby "notifiable transactions" must be reported to the CRA
    • Requirement to disclose "uncertain tax treatments"
  • Avoidance of Tax Debts
    • Strengthening the existing rules in the Tax Act which prevent taxpayers from avoiding their tax liabilities by transferring assets to non-arm's length parties
  • Supporting clean energy

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