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ARTICLE · 11 APRIL 2022

The Stikeman Elliott Federal Budget Commentary 2022

New rules with respect to hedging and short selling by Canadian financial institutions

CanadaTax

Stikeman Elliott's Tax Group has prepared a commentary on the 2022 federal budget.

Welcome to the Grand Illusion

Highlights:

  • Changes to address investment income earned and distributed by a private corporation that is "in substance", but is not technically, a Canadian-controlled private corporation
  • Potential new minimum tax for high earners
  • Amendments to the general anti-avoidance rule to address unused tax attributes
  • New taxes applicable to banks and life insurers
  • New rules with respect to hedging and short selling by Canadian financial institutions
  • Expansion of the scope of existing interest coupon stripping rules
  • Elimination of oil, gas, and coal flow-through shares and introduction of a new critical mineral exploration tax credit for flow-through share investors

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