Joint Committee, "August 2022 legislative proposals relating to the Income Tax Act and the Income Tax Regulations", 16 February 2023 Joint Committee Submission

Summary Under
Tax Topics - Income Tax Act - Section 85.1 - Subsection 85.1(4)

Elimination of purpose test (p. 2)

  • Given the breadth of the “series of transactions” concept, the proposed elimination of the purpose test...

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Summary Under
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(b) - Subparagraph 95(2)(b)(i) - Clause 95(2)(b)(i)(B)

Failure of s. 95(2)(b)(i)(B) amendments to address a partnership structure (pp. 6-7)

  • The s. 95(2)(b)(i)(B) amendments address that, under current...

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Summary Under
Tax Topics - Income Tax Act - Section 95 - Subsection 95(3.03)

Need to assimilate ancillary provisions to s. 95(3.03) tests (p. 7)

  • Although proposed s. 95(3.03) is modelled on the provision of relief in...

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