Canada: Department of Finance Draft Tax Legislative Proposals (Consultation process)

From Finance Canada website:

“July 31, 2015 – Ottawa, Ontario – Department of Finance

The Department of Finance today released for consultation draft legislative proposals that would implement certain tax measures from Economic Action Plan 2015.

These proposals include:


Business Income Tax

Modifying the dividend rental arrangement rules to deny the inter-corporate dividend deduction on dividends received by a taxpayer on a Canadian share where there is a synthetic equity arrangement. The draft legislative proposals include adjustments to the effective date of this measure.

Strengthening an existing anti-avoidance rule that prevents corporations from converting their capital gains into tax-deductible inter-corporate dividends.

International Taxation

Providing an exception to the withholding requirements for payments by qualifying non-resident employers to qualifying non-resident employees. The draft legislative proposals reflect comments received since the announcement of this measure in Economic Action Plan 2015.

Amending an existing anti-avoidance rule in Canada’s foreign accrual property income rules to ensure that profits of a Canadian taxpayer derived from the insurance of Canadian risks remain taxable in Canada.”

Comments by interested parties are due, at the latest, by September 30, 2015 (

The Legislative Proposals Relating to the Income Tax Act and Regulations are available here.

The Explanatory Notes Relating to the Income Tax Act and Regulation are available here.

We will have some comments in due time…

Robert Robillard, Ph.D., CPA, CGA, MBA, M.Sc. Econ.
Senior Partner, DRTP Consulting Inc.
514-742-8086; robertrobillard “at”

DRTP Consulting Inc. solutions go beyond transfer pricing and international tax solutions. The information in this blog post is general information only. Data and information come from sources believed to be reliable but complete accuracy cannot be guaranteed. DRTP Consulting Inc. or the author are not responsible or liable for any error, omission or inaccuracy in such information. The opinions expressed in this blogpost are those of the author. Readers should seek advice and counsel from DRTP Consulting Inc. as required.

Posted by drtp On 4 August 2015