The Stikeman Elliott Federal Budget Commentary 2018

Stikeman Elliott's Tax Group has prepared a commentary on the 2018 federal budget. Download: English (148.6 Kb), French (426.4 Kb)

Highlights include:

Business Tax Measures

  • Substantial pullback on passive income proposals
  • Additional rules to prevent “artificial” losses of financial institutions
  • Green v. R. (FCA) overturned – limited partnership losses still trapped in tiered partnerships

International Tax Measures

  • Extension of cross-border surplus stripping rule to use of partnerships and trusts
  • Foreign affiliate amendments to shutdown “tracking arrangements”

Sales and Excise Tax Measures

  • Slight modifications to previous proposals in respect of HST on management services provided to “investment limited partnerships”
  • New federal excise duty for cannabis