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Royal Assent for 2018 Federal Budget Bill #2

Royal Assent for 2018 Federal Budget Bill #2

These corporate income tax measures from the 2018 budget are now law


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Bill C-86 received Royal Assent on December 13, 2018. This bill implements certain measures announced in the 2018 budget (among other things).

Since Bill C-86 received first reading on October 29, 2018, the corporate income tax measures that it introduces are considered to be substantively enacted for purposes of IFRS and Accounting Standards for Private Enterprise (ASPE) as of that date (as Canada has a majority government). However, its corporate income tax measures are considered enacted for U.S. GAAP purposes on the date it received Royal Assent, December 13, 2018.

  • This bill includes the following corporate income tax measures proposed in the 2018 budget:
  • Changes to the at-risk rules for limited partnerships
  • Changes related to synthetic equity arrangements and securities lending arrangements
  • Amendments to the dividend stop-loss rules on share repurchase transactions
  • Certain international tax changes, including amendments related to cross-border surplus stripping using partnerships and trusts
  • Foreign affiliate proposals relating to investment businesses, controlled foreign affiliate status, trading or dealing in indebtedness, reassessments and reporting requirements
  • Amendments affecting the thin capitalization rules, specifically, clarifying the definition of "equity amount" in subsection 18(5) to exclude certain contributed surplus
  • Amendments to limit the amount of contributed surplus that can be converted to paid up capital without triggering a deemed dividend.

Bill C-86 also includes previously announced corporate income tax measures related to:

  • Allocating losses for RDTOH, as a consequence of the newly introduced eligible and non-eligible RDTOH pools
  • Corporations that are divided under foreign laws.

The bill also contains a number of other amendments including changes impacting indirect tax, personal tax, assessment periods and T1134 filing deadlines.

For more information, contact your KPMG adviser.

Information is current to December 18, 2018. The information contained in this publication is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavour to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act upon such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's National Tax Centre at 416.777.8500

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