Joint Committee, "July 27, 2018 Legislative Proposals", 10 September 2018 Submission

Summary Under
Tax Topics - Income Tax Act - Section 150 - Subsection 150(1.2)

Narrowness of the exceptions (pp. 3-6)

The exceptions in ss. 150(1.2)(a) to (n) are too narrow:

  • Re s. 150(1.2)(b): its $50,000 limit should be...

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Summary Under
Tax Topics - Income Tax Act - Section 163 - Subsection 163(6)

Penalty should not apply to s. 94 trust (pp. 6-7)

The s. 163(6) penalty should be reconsidered and, in any event, should not apply to a s. 94...

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Summary Under
Tax Topics - Income Tax Act - Section 96 - Subsection 96(2.1) - Paragraph 96(2.1)(f)

Alternatives to proposal of denying excess lower-tier losses (pp. 8-10)

There will be no ability to carryover unutilized limited partnership...

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Summary Under
Tax Topics - Income Tax Act - Section 212.1 - Subsection 212.1(6) - Paragraph 212.1(6)(b)

Look-through of corporations (pp. 12-13)

S. 212.1(6)(b), which applies a look-through rule for the purpose of having s. 212.1 apply on a...

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Summary Under
Tax Topics - Income Tax Act - Section 95 - Subsection 95(12)

Frequent need for Canadian investors in umbrella funds to make the election (pp. 13-14)

Where foreign investment funds are structured as corporate...

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