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This
document was prepared by the staff of the Parliamentary Research Branch
to provide Canadian Parliamentarians with plain language background and
analysis of proposed government legislation. Legislative summaries are
not government documents. They have no official legal status and do not
constitute legal advice or opinion. Please note, the Legislative Summary
describes the bill as of the date shown at the beginning of the document.
For the latest published version of the bill, please consult the parliamentary
internet site at www.parl.gc.ca.
LS-401E
BILL C-22: AN ACT TO AMEND
THE INCOME TAX ACT
AND RELATED STATUTES
Prepared by:
Blayne Haggart
Economics Division
18 April 2001
Revised 28 September 2001
LEGISLATIVE HISTORY OF BILL
C-22
HOUSE
OF COMMONS
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SENATE
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Bill
Stage |
Date |
Bill
Stage |
Date |
First
Reading: |
21 March
2001
|
First
Reading: |
15 May 2001
|
Second
Reading: |
23 April
2001
|
Second
Reading: |
30 May 2001
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Committee
Report: |
9 May 2001
|
Committee
Report: |
7 June 2001
|
Report
Stage: |
11 May 2001
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Report
Stage: |
|
Third
Reading: |
14 May 2001
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Third
Reading: |
12 June 2001
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Royal Assent: 14 June 2001
Statutes of Canada 2001, c.17
N.B. Any substantive changes in this Legislative
Summary which have been made since the preceding issue are indicated
in bold print.
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|
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TABLE
OF CONTENTS
OVERVIEW
SUMMARY
OF MAJOR AMENDMENTS
1.
Five-Year Tax-Reduction Plan
2.
Child Care Expense Deduction (clause 42)
3.
Disability Tax Credit (clauses 96 and 97)
4.
Caregiver and Infirm Dependant Tax Credits (clauses 93, 43, 98)
5.
Medical Expense Tax Credit (clause 95)
6.
Donations of Ecological Gifts (clauses 22, 27, 31, 85, 94, 158, 159, 170)
7.
Scholarships, Fellowships and Bursaries (clause 39)
8.
Education Tax Credit (clauses 98, 99, 101)
9.
Clergy Residence Deduction (clause 3)
10.
CPP/QPP Contributions on Self-Employed Earnings (clauses 41, 100)
11.
Thin Capitalization (clause 9)
12.
Non-Resident-Owned Investment Corporations (clauses 131 and 132)
13.
Weak Currency Debt (clauses 9, 14)
14.
Government Assistance SR&ED (clause 118)
15.
Foreign Tax Credits Oil and Gas Production Sharing Agreements (clause
117)
16.
Foreign Exploration and Development Expenses (FEDE) (clauses 44, 47, 49,
86, 87, 90, 117, 188)
17.
Flow-Through Share Investment Tax Credit (clause 118)
18.
Foreign Branch Banking
19.
Capital Dividend Account (clause 67)
20.
Taxpayer Migration (clauses 52, 79, 123-125, 54, 102, 117, 130, 149, 150,
154-156, 160, 161, 178)
21.
Trusts
22.
Advertising Expenses (clauses 11 and 12)
23.
Simultaneous Control (clause 194)
24.
Foreign Affiliates Held by Partnerships (clauses 68-71)
25.
Foreign Affiliate Losses (clause 73)
26.
Stop-Loss Rule (clauses 25, 102, 138, 160-161)
27.
Types of Property (clause 38)
28.
Limited Liability Partnerships (clauses 25, 74)
29.
Non-Resident Film and Video Actors (clauses 90, 151, 173-175)
30.
$1,000 Tax-Free Amount for Emergency Service Volunteers (clause 60)
31.
Alternative Minimum Tax (clauses 119, 121)
32.
Compliance (clause 182)
33.
Provision of Information (clauses 186, 184)
34.
Prescribed Stock Exchange (clause 188)
35.
GST Tax Credit (clause 107)
36.
Definitional Changes (clause 188)
37.
Insurance Corporations (clauses 9, 133)
38.
Winding Up of a Corporation (clause 66)
39.
Corporate Tax Reduction (clauses 111-113)
40.
Harmonization with the Civil Code of Quebec (clauses 196-237)
CLARIFICATIONS,
AND TECHNICAL AND MINOR AMENDMENTS
BILL C-22: AN ACT
TO AMEND THE INCOME TAX ACT
AND RELATED STATUTES*
OVERVIEW
Bill C-22, the Income Tax
Amendments Act, 2000, introduces many of the proposals put forth by the
government in its February 2000 budget and the subsequent economic statement
and budget update in October 2000. It also reintroduces a variety
of measures originally included in Bill C-43, which received first reading
in September 2000, but died on the Order Paper with the calling
of the November 2000 general election.
Most of the bill proposes
changes to the Income Tax Act. These include significant
cuts to personal income tax rates, and to the capital gains inclusion
rate. It also proposes a number of changes to various tax-credit
plans, and introduces more favourable treatment of stock options.
On the business side, a significant number of amendments address the taxation
of trusts, the treatment of foreign banks in Canada, and resource tax
credits.
The Bill also includes a
large number of minor and technical amendments, including minor amendments
to other Acts. These are listed at the end of the legislative summary.
This legislative summary
draws from the summary of Bill C-22 provided by the Department of Finance.
It is organized by major budgetary initiative, rather than a chronological
exposition of the Bill.
SUMMARY
OF MAJOR AMENDMENTS
1. Five-Year
Tax-Reduction Plan:
a. Reduce tax
rates at all income levels (clause 92; consequential amendments:
clauses 108, 120).
Year 2000
|
Applies to income
between
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Year 2001
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Applies to income
between
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17%
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$0-$30,004
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16%
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$0-$30,754
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25%
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$30,004-$60,009
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22%
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$30,754-$61,509
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29%
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$60,009+
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26%
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$61,509-$100,000
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|
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29%
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$100,000+
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At the end of the five-year
period, the income thresholds will not be less than $35,000, $70,000
and $113,804, respectively, regardless of the annual increase provided
for by indexation.
b. Eliminate
the 5% deficit reduction surtax as of January 2001 (clauses 160-161;
consequential amendments: clauses 148, 152, 157).
c. Increase
support for families through the Canada Child Tax Benefit (clauses 109,
110).
d. Reduce the
capital gains inclusion rate (clauses 5, 6, 7, 13, 16, 22-24, 26, 36,
38, 58, 59, 61, 67, 70, 73, 74, 76-78, 80, 84, 86-88, 91, 119, 127-129,
134, 156, 177, 187, 250)
-
The 2000 budget promised
a reduction in the capital gains inclusion rate from three-quarters
to two-thirds effective 28 February 2000, while the budget update
further reduced the rate to one-half effective 18 October 2000.
Bill C-22, through many proposed amendments to many parts of the
Income Tax Act, would implement these changes.
e. Provide
a tax-deferred capital-gains rollover for investments in shares of certain
small- and medium-sized active business corporations (clauses 28, 29,
52).
f. Provide
a tax-deferred rollover for shares received on certain foreign spin-offs
(clauses 63-65, 73, 74, 83, 169).
g. Stock Options
(clauses 2, 32, 36, 84; 31,78, 87, 90, 122)
The new legislation proposes
to:
-
Defer the taxation
of certain (employee) stock option benefits acquired after 27 February
2000. Under the proposed changes, employees will be able to
defer the income inclusion from exercising employee stock options
for publicly listed shares until the disposition of the shares,
subject to a $100,000 annual vesting limit. Employers will
not be required to track disposition of shares acquired under a
stock option plan. The deadline for this is 60 days after
the legislation providing the deferral receives Royal Assent.
2. Child
Care Expense Deduction (clause 42)
3. Disability
Tax Credit (clauses 96 and 97)
-
Extends the disability
tax credit to individuals who, but for extensive therapy, would be
markedly restricted in their activities of daily living;
-
Provides a supplement
for disabled children under the age of 18 years;
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Extends the transferability
of the credit to most relatives of a disabled person; and
-
Starting in 2001, increases
the amounts on which the credit and the new supplement are calculated
to $6,000 and $3,500 from $4,293 and $2,941, respectively.
4. Caregiver
and Infirm Dependant Tax Credits (clauses 93, 43, 98)
-
Increases the amount
on which each of these credits is calculated to $3,500 from $2,446,
and expands it to allow a taxpayer to claim the tax credit for such
relatives of the taxpayers spouse or common-law partner.
-
Expands the list of
eligible sources of income; extends the deduction up to a maximum
of $10,000 to an individual who incurs attendant care expenses to
attend a designated educational institution or high school.
5. Medical
Expense Tax Credit (clause 95)
-
Includes reasonable
incremental costs relating to the construction of the principal place
of residence of an individual who lacks normal physical development
or has a severe and prolonged ability impairment to enable the individual
to gain access to, or to be mobile within, the residence.
6. Donations
of Ecological Gifts (clauses 22, 27, 31, 85, 94, 158, 159, 170)
-
Halves the normal capital
gains inclusion (to one-quarter) for an ecological gift the value
of which has been certified by the Minister of the Environment; and
clarifies rules for calculating any capital gain or loss realized
as a result of such a gift.
-
In addition to its rules
related to the donation of ecologically sensitive lands, clause 94
also proposes amendments regarding charitable gifts in general (e.g.,
charitable donations, gifts to the Crown and certain gifts of cultural
property). Specifically, it proposes extending the charitable
donations tax credit to eligible transfers under a life insurance
policy or from an RRSP or a registered retirement income fund (other
than a plan or fund of which a license annuities provider
is the issuer or carrier) made as a consequence of a qualified donee
being named a beneficiary. As a result, the credit can be claimed
on an individuals death as a consequence of transfers to qualified
donees.
7. Scholarships,
Fellowships and Bursaries (clause 39)
-
Increases the exemption
for scholarships, fellowships and bursaries received by a taxpayer
in connection with the taxpayers enrolment in a program for
which the taxpayer may claim the education tax credit, from $500 to
$3,000.
8. Education
Tax Credit (clauses 98, 99, 101)
9. Clergy
Residence Deduction (clause 3)
-
Provides clearer rules
for determining the amount deductible for a clergys residence,
limiting this deduction, in the case where the clergy person provides
his or her own residence to: the lesser of the clergy persons
total remuneration from the office or employment; one-third of that
total remuneration or $10,000, whichever is greater; and the fair
rental value of the residence (reduced by other amounts deducted in
connection with the same residence). These rules are to apply
to the 2001 and subsequent taxation years.
10. CPP/QPP
Contributions on Self-Employed Earnings (clauses 41, 100)
11.
Thin Capitalization (clause 9)
-
Amends the provisions
to have the debt-to-equity ratio calculated on an averaged basis,
reduces the acceptable debt-to-equity ratio to 2:1 from 3:1, and repeals
the exemption for manufacturers of aircraft and aircraft components.
12.
Non-Resident-Owned Investment Corporations (clauses 131 and 132)
13.
Weak Currency Debt (clauses 9, 14)
14. Government
Assistance SR&ED (clause 118)
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Categorizes, as government
assistance, provincial deductions for SR&ED that exceed the amount
of the SR&ED expenditures.
-
Clause 21 provides for
the reduction of a corporations SR&ED pool for a taxation
year by its super-allowance benefit amount for the year and preceding
taxation years.
15.
Foreign Tax Credits Oil and Gas Production Sharing Agreements (clause
117)
-
Clarifies the eligibility
for a business foreign tax credit of certain payments made by Canadian
resident taxpayers to foreign governments on account of levies imposed
in connection with production sharing agreements.
-
Clause 5 ensures that
any production tax amount of the taxpayer for a foreign
oil and gas business is included in computing the taxpayers
income.
16.
Foreign Exploration and Development Expenses (FEDE) (clauses 44, 47, 49,
86, 87, 90, 117, 188)
-
Amends the rules to
require that the FEDE of a claimant must relate to either foreign
resource property acquired by the claimant or be made for the purpose
of enhancing the value of foreign resource property owned, or to be
owned, by the claimant.
-
Ensures appropriate
treatment of FEDE in computing foreign tax credits.
-
Imposes a 30% restriction
for the annual deduction of new FEDE balances.
-
Clause 47 proposes rules
governing foreign resource expenses (FRE), defined essentially the
same way as the FEDE, except there are separate FRE accounts for each
country to which FRE relates. FRE is explicitly excluded from
the amended definition of FEDE. Subsection 66.21(4) permits
a deduction for a taxpayers cumulative FRE for each country.
The limit of the deduction is not less than 10% of the taxpayers
cumulative FRE for the country at the end of the taxation year, and
is not more than the full amount of the balance. Consequential
amendments are found in clauses 13, 15, 20, 36, 40, 44, 49, 50, 52,
58, 65, 66, 74, 78, 86, 87, 90, 117, 119, 188.
17. Flow-Through
Share Investment Tax Credit (clause 118)
-
Introduces a temporary
15% investment tax credit for certain grass roots mineral
exploration. These include expenses incurred in determining
the existence or location, and the extent
or quality, of a mineral resource (clause 45).
18.
Foreign Branch Banking
-
Provides amendments
to the Income Tax Act to accommodate branches of foreign banks
operating in Canada (clauses 14, 19, 90, 117, 169, 137, 151, 153,
173, 176, 184, 188, 190).
-
These include extended
provisions relating to eligible Canadian affiliates and foreign
mergers, extended exclusion of benefit and deemed disposition provisions,
more extensive reserve continuity, extension of the deadlines for
conversion relief, relaxation of the requirement that dissolution
be completed before losses of a regulated entity can be accessed,
and more explicit stop-losses provisions (clause 138).
-
It also proposes amendments
relating to OSFI-filed financial statements, use of OSFI-filed financial
statements for computation of income, exemption from the certificate
requirement on the sale of taxable Canadian property, pro-rating
of the capital tax base based on the proportion of Canadian assets,
exclusion from foreign property treatment, and exclusion of representative
offices from the scope of Canadian banking business
(clauses 163, 165-167, 168).
-
These proposed changes
are designed to make Canadas taxation of commercial-focused
foreign-bank branches broadly comparable to the taxation of Canadian
banks (clauses 9, 87).
-
The bill also includes
incidental proposals in other tax areas, including a proposal that
foreign currency deposits be permitted investments for Registered
Retirement Savings Plans and other deferred-income plans (clauses
139-142).
19.
Capital Dividend Account (clause 67)
20.
Taxpayer Migration (clauses 52, 79, 123-125, 54, 102, 117, 130, 149, 150,
154-156, 160, 161, 178)
-
Enhances Canadas
ability to tax the gains accrued by emigrants while they were resident
in Canada.
-
Several amendments also
adjust the rules concerning non-residents taxable activities
in Canada (clauses 4, 7 (consequential amendments: clauses 57,
62, 74, 75), 8, 25 (consequential amendments: clauses 128, 129,
177, 249), 30, 36, 56, 57, 73, 90, 147, 149, 191).
-
Clause 89 proposes amendments
to the rules governing the calculation of the taxable income of a
part-year resident of Canada (consequent amendments are proposed in
clauses 86, 87, 106, 117, 18).
-
Clause 178 proposes
rules allowing an individual to defer payment of tax owing due to
the disposition of a particular property by providing appropriate
security in lieu of the tax. If this is done, interest does
not start to accrue on the amount secured until the amount becomes
unsecured.
21.
Trusts
-
A large number of the
proposed amendments in Bill C-22 address the tax treatment of trusts.
The most significant changes are outlined below.
-
Proposed amendments
related to the tax treatment of property distributed from a Canadian
trust to a non-resident beneficiary are found in clauses 80 ss. 107(5),
83, 150, 169, 171, 172, 178. Clause 150 extends the normal reassessment
period under s. 152(3.1) for certain trust distributions of taxable
Canadian property to non-resident beneficiaries.
-
Several clauses address
the tax treatment of property distributed from trusts to their beneficiaries
(clauses 36, 72, 78, 80) and the taxation in Canada of income earned
by a non-resident trust deemed resident in Canada.
-
Clause 178 proposes
rules allowing a trust to defer payment of tax owing due to the disposition
of a particular property by providing appropriate security in lieu
of the tax. If this is done, interest does not start to
accrue on the amount secured until the amount becomes unsecured.
-
Bill C-22 proposes new
measures dealing with the tax treatment of:
a. bare, protective
and similar trusts (clauses 78, 82, 83, 188); as well as
b. mutual fund
trusts (clauses 129, 130, 169, 193, 83);
c. health and
welfare trusts (clause 83); and
d. trusts governed
by registered retirement savings plans and registered retirement income
funds (clauses 53, 55, 80, 82, 169, 188).
-
Clauses 27, 35, 80 (subsection
107(2) and (2.1)), 83 and 188 are part of a set of amendments designed
to clarify the tax consequences of distributions from trusts to their
beneficiaries after 1999.
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Clauses 36, 51, 78,
80, 105 and 192 propose changes to the treatment of changes in trust
ownership where there is no beneficial change in ownership.
Clause 53 extends the tax-free disposition of capital property from
an individual to a trust for the exclusive benefit of the individuals
spouse or common-law partner during that persons lifetime, to
include a transfer property to a trust for the exclusive benefit of
the individual, or for the joint benefit of the individuals
spouse or common-law partner.
-
Several proposed amendments
restrict the exemption from the 21-year rule for trusts in which all
interests have vested indefeasibly to cases where the beneficiaries
are all resident in Canada. This exemption is in paragraph (g)
of the definition trust in subsection 108(1) (clause 83).
A related relieving amendment to subsection 104(5.8) (clause 78) provides
that the date of the 21-year anniversary for such a trust is determined
without reference to the special transfer rules for trusts in ss.
104(5.8), if the transfer occurred on or before 24 December 1998.
Further proposed amendments related to the 21-year deemed disposition
rule are found in clauses 52, 55, 78, 80, 81, 86 (ss. 108(6)),
171 and 172.
-
The treatment of income
interest in a trust is addressed in clauses 79, 80 and 83 (in the
definition of capital income). The proposed amendments
under clause 79 aim to assure that there is no double taxation on
the disposition of an income interest in a trust.
22.
Advertising Expenses (clauses 11 and 12)
-
Implements the income
tax aspects of the June 1999 agreement between Canada and the United
States concerning periodicals. It will permit full deductibility
of expenses for advertisements published in periodicals that contain
at least 80% original editorial content, and 50% deductibility for
advertising expenses in other periodicals, regardless of the ownership
of the periodical.
23. Simultaneous
Control (clause 194)
24.
Foreign Affiliates Held by Partnerships (clauses 68-71)
25.
Foreign Affiliate Losses (clause 73)
26.
Stop-Loss Rule (clauses 25, 102, 138, 160-161)
27.
Types of Property (clause 38)
28.
Limited Liability Partnerships (clauses 25, 74)
29.
Non-Resident Film and Video Actors (clauses 90, 151, 173-175)
30.
$1,000 Tax-Free Amount for Emergency Service Volunteers (clause 60)
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Replaces the current
deduction of up to $1,000 for compensation received by volunteer emergency
service providers with a corresponding exclusion from employment income
for income tax purposes. This change will have no income tax
implications for volunteer emergency service providers. Heating
expenses cheques and some travel expenses are excluded from income
for tax purposes.
31. Alternative
Minimum Tax (clauses 119, 121)
-
Consequent to the lowering
of the capital gains tax, the capital gains inclusion rate for alternative
minimum tax (AMT) purposes is to be reduced to 80%; 40% of the stock
option deduction claimed in calculating regular income tax for taxable
stock option benefits is to be deductible in calculating taxable income
for AMT purposes.
-
The amendments include
other items in the deduction that may be taken into consideration
when determining adjustable taxable income.
32. Compliance
(clause 182)
-
Expands the prohibition
on hindering, molesting or interfering with an official performing
certain administrative and enforcement functions under the Income
Tax Act to include any act that the official is authorized under
the Act to perform.
-
Alternative means of
enforcing compliance are included under new section 231.7 (clauses 183,
181).
-
Related amendments are
proposed for the Excise Tax Act (clauses 257-259).
33. Provision
of Information (clauses 186, 184)
-
The Canada Customs and
Revenue Agency (CCRA) is allowed to disclose taxpayer information
for business activities carried on in a province to provincial statistical
agencies, only where such information is to be used by the provincial
agency solely for research and analysis and that agency is authorized
under the law of the province to collect the same or similar information
on its own behalf for such business activities. Information
can also be provided to a police officer solely for the purpose of
investigating whether an offence has been committed, or the laying
of an information or the preferring of an indictment, where:
-
such information can
reasonably be regarded as being relevant for the purpose of ascertaining
the circumstances in which an offence under the Criminal Code
may have been committed, or the identity of the person who may have
committed an offence, with respect to an official (or a person related
to that official);
-
the official was or
is engaged in the administration or enforcement of the Income
Tax Act; and
-
the offence can reasonably
be considered to be related to that administration or enforcement.
34. Prescribed
Stock Exchange (clause 188)
35.
GST Tax Credit (clause 107)
-
This clause proposes
the removal of the GST tax credit for individuals imprisoned during
the 12-month period ending 30 June 2002 for the 2000 taxation year
(i.e., GST payments made in July and October 2001, and January and
April 2002). This short timeline anticipates a more general
reform of the GST tax credit.
36. Definitional
Changes (clause 188)
a. alter
ego trust;
b. disposition
(with consequential amendments to clauses 6, 25, 34, 36, 37, 40, 48,
78, 80, 130), which has implications for many of the clauses involving
trusts;
c. foreign
resource pool expenses, foreign resource property;
d. joint
spousal or common-law partner trust; and
e. taxable
Canadian property (clarifies the existing definition of taxable
Canadian property; with consequential amendments found in clauses
25, 36, 65, 90, 91, 123, 128, 129, 131, 135, 177, 249).
37.
Insurance Corporations (clauses 9, 133)
-
Clause 9 (section 18(9.02))
proposes the introduction of a technical amendment regarding the timing
of certain deductible expenses.
-
Amendments in clause
133 address insurance corporations. They suggest changes to
the tax treatment of interest on borrowed money used to acquire designated
insurance property.
38.
Winding Up of a Corporation (clause 66)
39. Corporate
Tax Reduction (clauses 111-113)
-
Clause 112 proposes
rules to allow a corporation to reduce its tax payable by a percentage
of the corporations full rate taxable income, increasing
in stages from 1% for 2001 to 7% after 2003. Investment corporations,
mortgage investment corporations, mutual fund corporations, and non-resident
owned investment corporations are not eligible. Canadian-controlled
private corporations (CCPCs) would receive an additional rate reduction,
equal (in broad terms) to 7% of up to $100,000 of the CCPCs
active business income over the amount that benefits from the special
rate for small business income under section 125.
-
Clause 111 proposes
that the 4% corporate surtax will be calculated on federal income
tax payable before taking into account the proposed tax reduction
in clause 112.
40. Harmonization
with the Civil Code of Quebec (clauses 196-237)
CLARIFICATIONS,
AND TECHNICAL AND MINOR AMENDMENTS
-
Clause 10: matchable
expenditure rules regarding reinsurance
-
Clause 13: deductions
for business outlays
-
Clause 37: definition
of principal residence
-
Clause 103: amendment
in recognition of lower provincial tax rates
-
Clause 103: refers
to a part of the Act that no longer exists
-
Clause 113: Small
business deduction
-
Clause 114: Manufacturing
and processing profits deduction (also extends this deduction to the
production of steam for sale)
-
Clause 115: Canadian
film or video production tax credit (see also clause 156)
-
Clause 116: Canadian
film or video production services tax credit (see also clause 156)
-
Clause 126: closes
a loophole of a transitional rule regarding the disposition of property
before 13 November 1981
-
Clause 135: Exclusion
from taxable Canadian property (changes numbering)
-
Clause 143: Employees
pension contributions deductions
-
Clause 144: Transfer
to RPP, RRSP or RRIF for spouse on Marriage Breakdown
-
Clause 145: Miscellaneous
Exemptions
-
Clause 146: National
Arts Service Organizations
-
Clause 162: Corrects
an oversight to the recovery of Old Age Security Benefits
-
Clause 164: connected
corporations: confusing
-
Clause 179: collection
restrictions
-
Clause 180: withholding
taxes (application to Crown)
-
Clause 186: provision
of information by CCRA on a registered charity that no longer exists
-
Clause 187: transfer
pricing (French-English concordance)
-
Clause 189: definition
of fiscal period
-
Clause 195: deemed
interest on preferred shares, corrects a cross-reference
-
Clauses 238-248, 252,
253
-
Canadian Pension
Plan: Clause 254 (computing a persons income under
the Income Tax Act)
-
Customs Act:
Clauses 255 and 256 (hindering an officer)
-
Excise Tax Act:
Clause 257 (compliance);
-
Modernization of
Benefits and Obligations Act: Clause 263 (misprint)
-
Sales Tax and Excise
Tax Amendments Act, 1999: Clause 264 (French version concordance)
*
Notice: For clarity of exposition, the legislative proposals set
out in the Bill described in this Legislative Summary are stated as
if they had already been adopted or were in force. It is important
to note, however, that bills may be amended during their consideration
by the House of Commons and Senate, and have no force or effect unless
and until they are passed by both Houses of Parliament, receive Royal
Assent, and come into force.
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