New Favourable CRA Position on Advances from Limited Partnerships

A recent CRA administrative position provides comfort in situations where a partnership distributes its current year cashflow to a limited partner as an advance. Distributions by a partnership to a partner generally reduce the adjusted cost base (“ACB”) of the partner’s interest in the partnership. On the other hand, partnership income allocated to the partner…

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New Obligations for Legal Entities

About the new obligations for corporate transparency On June 3rd, 2021, the Québec Government enacted Bill 78, An Act mainly to improve the transparency of enterprises (the “Act“), with the objective of providing better protection to the public by contributing to the prevention and fight against tax evasion, money laundering and corruption. The Act will come…

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New Trust Reporting Rules

On November 4, 2022, the Department of Finance announced that implementation of the new trust reporting rules – initially announced in the 2018 federal budget – will be delayed until 2023. Under the current rules, a trust is generally only required to file an annual income tax (T3) return if the trust has tax payable…

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New Proposed Restrictions on Interest Deductibility – Implementation Delayed –

On February 4, 2022, the Department of Finance proposed important changes that will affect the amount of interest and financing expenses deductible by certain taxpayers. These new restrictions are known as the Excessive Interest and Financing Expenses Limitation (“EIFEL”) regime. Overview In general terms, the new EIFEL rules will limit the amount of net interest…

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